Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Limited In Name Only – Second Circuit Narrows The Path For Self-employment Tax Partnership Planning
The Second Circuit's ruling in Soroban Capital Partners LP v. Commissioner establishes that a "limited partner" must have both limited liability and no role in running, managing, or controlling the partnership to qualify for the self-employment tax exception. This decision, alongside the Fifth Circuit's revised opinion in Alain v. Commissioner, creates a circuit split with significant implications for fund managers who structure ownership through limited partnerships to minimize self-employment tax
United States Tax
WT
Winston Taylor
Article
City Of New Orleans Announces Sales Tax Amnesty Program
The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.
United States Tax
LL
Liskow & Lewis
Article
Proposed Nondiscrimination Rule For Private School Admissions, Financial Assistance, And Other Programs
The IRS has proposed new regulations that would impose nondiscrimination requirements on private schools seeking to maintain their tax-exempt status under section 501(c)(3). These regulations would prohibit policies discriminating on the basis of race, color, or national or ethnic origin in admissions, financial assistance, and other school programs. The proposed rules raise important questions about how private schools can structure their programs while complying with federal tax law requirements.
United States Tax
JD
Jones Day
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Tax Disputes

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Inheritance Tax

Article
A $13 Million Reminder: Domicile Planning Is More Than Paperwork
A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.
United States Tax
WD
Wiggin & Dana
Article
A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act
California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United States Tax
WL
Withers LLP
Article
FASB’s New Fair Value Standard May Bolster Marketability Discounts In Estate Planning
The Financial Accounting Standards Board issued Accounting Standards Update 2026-03, Fair Value Measurement (Topic 820): Investment Companies with Equity Securities Subject to Contractual Sale Restrictions, on September 9, 2026. While the update is aimed at investment company accounting, it could benefit estate planners and valuation professionals who regularly defend marketability discounts on closely held and restricted stock.
United States Tax
LL
Liskow & Lewis
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Capital Gains Tax

Article
Existing Opportunity Zone Investors Must Evaluate Planning Opportunities Before Dec. 31, 2026
The IRS has issued Notice 2026-40 providing transition guidance for investors who deferred capital gains under the original Opportunity Zone program. While December 31, 2026 remains the mandatory recognition date for deferred gains, the guidance reveals a potential planning opportunity that may allow certain investors to continue deferring gains under the new Opportunity Zone regime through strategic pre-year-end transactions.
United States Tax
JM
Jeffer Mangels & Mitchell LLP
Article
GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation
The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.
United States Tax
RS
Rotfleisch & Samulovitch P.C.
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Property Taxes

Article
Residential Vacancy Tax Preempted By State Law
A California Court of Appeal has invalidated San Francisco's Empty Homes Tax, ruling that the Ellis Act—which protects property owners' right to exit the rental market—also shields them from being forced to enter it through vacancy taxation. This landmark decision raises critical questions about the viability of similar residential vacancy taxes that other California municipalities have enacted or are considering as housing policy tools.
United States Real Estate
CC
Cox, Castle & Nicholson
Article
Are You Also Confused How New York City's Pied-à-Terre Tax Applies To You?
New York City's Pied-à-Terre Tax Law has created uncertainty for homeowners following the Department of Finance's adoption of final rules and mailing of thousands of surcharge notification letters. This comprehensive analysis examines the tax's application to residential properties, clarifies common scenarios involving trusts and business entities, and provides guidance on exemption qualifications and appeal procedures before the October 6, 2026 deadline.
United States Tax
HK
Holland & Knight
Article
GT SALT Team On The Move (September–October 2026 Digest)
Greenberg Traurig's State and Local Tax team is hitting the road this fall with a packed schedule of speaking engagements at premier tax conferences across the country. From the COST Annual Meeting in San Antonio to the Hartman SALT Forum in Nashville, GT attorneys will address critical topics including legislative updates, apportionment issues, property tax developments, and multistate planning strategies that are shaping the state tax landscape.
United States Tax
GT
Greenberg Traurig, LLP
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Tax Treaties

Article
US Expats Face Another Tax Setback In The Courts: Is It Time To Finally Renounce US Citizenship?
Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.
United States Tax
MP
Moodys Private Client Law LLP
Article
US Federal Court Considers The Implications For Canadian Exempt Organizations Earning US Source Income Through An Intermediary Vehicle
The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment
United States Tax
TL
Torys LLP
Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.
United States Tax
HL
Hogan Lovells Cadwalader
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