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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.

Treasury Issues Transition Guidance For Taxpayers With One-month Deferral Elections

The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election...

United States Tax

SR

McDermott Will & Schulte

Fifth Circuit Overrules Tax Court, Providing Major Victory For Limited Partners On Self-Employment Tax

In a significant decision for the investment funds industry, the U.S. Court of Appeals for the Fifth Circuit has officially rejected the Internal Revenue Service (IRS)'s "passive investor" test for the limited partner self-employment tax exception...

United States Tax

AG

Akin Gump Strauss Hauer & Feld LLP

Sales And Use Tax 2026 Updates In North Carolina: What Business Owners Need To Know

The North Carolina Department of Revenue published its 2026 Sales and Use Tax Bulletins effective January 1, 2026. The bulletins include several notable updates providing new guidance on tariffs, parking fees...

United States Tax

YM

Young Moore and Henderson

GeTtin' SALTy Episode 68 | State Tax Revenues In 2026: Slow Growth, Flat Taxes, And Fiscal Uncertainty With Lucy Dadayan (Podcast)

In this episode of GeTtin' SALTy, host Nikki Dobay welcomes back Lucy Dadayan, Principal Research Associate at the Urban-Brookings Tax Policy Center, as they kickoff the first podcast episode of 2026.

United States Tax

GT

Greenberg Traurig, LLP

Final Regulations Provide Clarity On Tax Treatment Of Wholly Owned Tribal Entities

United States Tax

HK

Holland & Knight

How To Ensure Compliance With Spot Exchange Rate Requirements Under U.S. Federal Tax Law

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Importing Or Exporting More Than $10,000 In Cash? U.S. Reporting Laws, Federal Penalties, And Disclosure Considerations

United States Tax

RS

Rotfleisch & Samulovitch P.C.

The Relevance Of Relevance And The Economic Substance Doctrine

United States Tax

RP

Ruchelman PLLC

Supplementary Law No. 225/2026: Taxpayers' Defense Code

United States Tax

MB

Mayer Brown

Fifth Circuit Rules That Soroban Was Incorrectly Decided And SECA Tax Exception Applies To Limited Partners With Limited Liability Regardless Of Activities

United States Tax

ST

Simpson Thacher & Bartlett

2026 Government Relations Legislative Update - Week One

United States Tax

BW

BrownWinick Law

Sirius Solutions, L.L.L.P. V. Commissioner: Impact On SECA Tax For Limited Partners

United States Tax

KR

Kutak Rock LLP

5th Circuit Gives Taxpayers Sirius Victory In Self-Employment Tax Case

United States Tax

WS

Winston & Strawn LLP

Oecd Inclusive Framework Reaches Agreement On Pillar Two "Side-By-Side" Package

United States Tax

WG

Weil, Gotshal & Manges LLP

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Webinars

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Recorded on 20 Jan 2026 | 3:00 PM

2026 Canadian In-House Counsel Report: Unparalleled Insights into Canada's In-House Profession from CBA In-House Lawyers

TC

CBA In-House Lawyers

Recorded on 9 Jul 2025 | 2:00 PM

Digital Assets – Innovation vs Compliance: Emerging Offshore Jurisdictional Trends – How Legal Advisers' Roles Will Change

W

Walkers

Recorded on 24 Jun 2025 | 3:00 PM

(2nd Session) 2025 Global In-House Counsel Survey Report: Unique Insights into the Global In-House Counsel Profession

IC

In-House Counsel Worldwide

Recorded on 24 Jun 2025 | 9:00 AM

(1st Session) 2025 Global In-House Counsel Survey Report: Unique Insights into the Global In-House Counsel Profession

IC

In-House Counsel Worldwide

Related Country Guides

Tax Treaties

The Relevance Of Relevance And The Economic Substance Doctrine

The economic substance doctrine in the U.S. has its roots in case law that aimed to deny tax benefits generated from certain abusive transactions entered into solely or primarily to obtain tax benefits.

United States Tax

RP

Ruchelman PLLC

IRS Criminal Voluntary Disclosure Program (VDP) Changes Take Effect In Early 2026: How Crypto Tax Disclosures And FATCA Reporting Obligations Affect U.S. Tax Compliance

The IRS has outlined plans to revise its Criminal Voluntary Disclosure Program (CVDP) in early 2026, with proposed rules aimed at improving consistency and predictability in handling willful tax noncompliance disclosures.

United States Tax

RS

Rotfleisch & Samulovitch P.C.

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review And Implications

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework)...

United States Tax

HK

Holland & Knight

Recent IRS Guidance On Branch Profits Tax Treaty Benefits For Foreign Reverse Hybrid Entities

United States Tax

FL

Foley & Lardner

New Section 892 Regulations: Action Points For Private Fund Sponsors And Non-U.S. Pension Plan & Sovereign Investors

United States Strategy

AG

Akin Gump Strauss Hauer & Feld LLP

Cross-border Trust Strategies: Maximising Jurisdictional Advantages

United States Commercial

GGI Global Alliance

An Increasingly Less Remote Situation: New O.E.C.D. Model Treaty Commentary On Remote Workers

United States Employment

RP

Ruchelman PLLC

Relevant International Updates

United States Tax

KM

Katten Muchin Rosenman LLP

IRS Guidance Clarifies Tax Treaty Benefits On Branch Profits Tax For Funds And Multinationals Using Reverse Hybrids

United States Tax

GT

Greenberg Traurig, LLP

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National Insurance

Autumn Budget 2025 – Pensions Aspects

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

United States Employment

MB

Mayer Brown

Autumn Budget 2025—the Pensions Angle

The Chancellor has today announced her highly anticipated autumn Budget.

United States Employment

AO

A&O Shearman

Payrolling Benefits Becomes Mandatory From 6 April 2026 - Are You Prepared?

From April 2026, payrolling Benefits in Kind (PBIK) will be mandatory. Employers are encouraged to voluntarily adopt the scheme by 2025/26 to prepare. Businesses must align payroll processes, ensure benefit data is real-time, and address communication, cost, and cash flow impacts.

United States Tax

AM

Alvarez & Marsal

A View On The Spring Budget 2024 (Video)

United States Tax

AM

Alvarez & Marsal

The Vermilion Case: Key Takeaways For Asset Managers Of The Supreme Court's Decision Covering The Application Of Deeming Provisions In The Employment-related Securities Legislation

United States Tax

AM

Alvarez & Marsal

Perfect Influence?

United States Tax

CW

Cadwalader, Wickersham & Taft LLP

BlueCrest Salaried Members Case: Who Is A Significant Influencer?

United States Tax

CW

Cadwalader, Wickersham & Taft LLP

A Tale Of Two Crowns: COVID-19 And The Return Of Crown Preference

United States Tax

FC

FTI Consulting

Intentional Accidents: California Supreme Court Announces That General Commercial Liability Policies Apply To Negligent Hiring, Training, And Supervising Claims For Failing To Prevent Intentional Torts

United States Insurance

CF

Carlton Fields

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Tax Authorities

Section 83(b) Elections: Why Founders Who Expect Their Company To Succeed Need To Pay Attention Early

In the early stages of most life sciences and other technology companies, momentum is driven by ideas that have future commercial value rather than immediate cash returns.

United States Commercial

C

Crowley Law LLC

100% Bonus Depreciation Returns — Are You Using The Right Strategy?

The One Big Beautiful Bill Act restores 100% bonus depreciation for eligible assets placed in service after January 19, 2025, offering private companies' new options.

United States Commercial

MG

MGO CPA LLP

Treasury Issues Transition Guidance For Taxpayers With One-month Deferral Elections

The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election...

United States Tax

SR

McDermott Will & Schulte

Fifth Circuit Overrules Tax Court, Providing Major Victory For Limited Partners On Self-Employment Tax

United States Tax

AG

Akin Gump Strauss Hauer & Feld LLP

Sales And Use Tax 2026 Updates In North Carolina: What Business Owners Need To Know

United States Tax

YM

Young Moore and Henderson

Governor Hochul Proposes $150 Million Boost To Broadway's Tax Incentives

United States Strategy

LB

Lewis Brisbois Bisgaard & Smith LLP

How To Ensure Compliance With Spot Exchange Rate Requirements Under U.S. Federal Tax Law

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Importing Or Exporting More Than $10,000 In Cash? U.S. Reporting Laws, Federal Penalties, And Disclosure Considerations

United States Tax

RS

Rotfleisch & Samulovitch P.C.

The Relevance Of Relevance And The Economic Substance Doctrine

United States Tax

RP

Ruchelman PLLC

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Income Tax

SECURE 2.0: Key Provisions And Tax Planning Implications For American Retirees

SECURE 2.0 strengthens the U.S. retirement system by expanding contribution opportunities, increasing flexibility for savers, and imposing new compliance obligations.

United States Tax

RS

Rotfleisch & Samulovitch P.C.

Section 83(b) Elections: Why Founders Who Expect Their Company To Succeed Need To Pay Attention Early

In the early stages of most life sciences and other technology companies, momentum is driven by ideas that have future commercial value rather than immediate cash returns.

United States Commercial

C

Crowley Law LLC

Treasury Issues Transition Guidance For Taxpayers With One-month Deferral Elections

The Internal Revenue Service (IRS) recently released Notice 2025-72 as a preview of forthcoming regulations addressing the repeal of the one-month deferral election...

United States Tax

SR

McDermott Will & Schulte

Fifth Circuit Overrules Tax Court, Providing Major Victory For Limited Partners On Self-Employment Tax

United States Tax

AG

Akin Gump Strauss Hauer & Feld LLP

Massachusetts 2026 Policy Outlook: Elections, Affordability, And Legislative Priorities

United States Energy

M

Mintz

GeTtin' SALTy Episode 68 | State Tax Revenues In 2026: Slow Growth, Flat Taxes, And Fiscal Uncertainty With Lucy Dadayan (Podcast)

United States Tax

GT

Greenberg Traurig, LLP

Final Regulations Provide Clarity On Tax Treatment Of Wholly Owned Tribal Entities

United States Tax

HK

Holland & Knight

OBBBA In 2026: Immediate Action Required For Employers

United States Employment

JL

Jackson Lewis P.C.

How To Ensure Compliance With Spot Exchange Rate Requirements Under U.S. Federal Tax Law

United States Tax

RS

Rotfleisch & Samulovitch P.C.

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Latest Videos

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Webinar – Washington's New Digital Sales Tax (Video)

BB

Beresford Booth

C Corporation: Pros & Cons For Startups (Taxes, Investors & Liability) (Video)

C

Crowley Law LLC

Maryland's Sales Tax On IT And Data Services (Video)

OK

Offit Kurman

Ten Minute Interview: Tax Cuts And Jobs Act (TCJA) (Video)

FL

Foley & Lardner

A View On The Spring Budget 2024 (Video)

AM

Alvarez & Marsal

Upcoming Events

Carolyn Schenck Discusses IRS Operations And Enforcement Priorities At FBA Tax Law Conference

United States Tax

CD

Caplin & Drysdale

Carolyn Schenck Addresses Criminal Enforcement And Exempt Organizations At TEGE Annual Exempt Organizations Update And Meeting

United States Tax

CD

Caplin & Drysdale

Peter Barnes Moderates Panel On AI And The Future Of Tax Administration At IBFD X C&D Planning For An AI Future In Cross-Border Tax Administration Conference

United States Tax

CD

Caplin & Drysdale

Victor Jaramillo Moderates Panel On AI And Alternative Dispute Resolution At IBFD X C&D Planning For An AI Future In Cross-Border Tax Administration Conference

United States Tax

CD

Caplin & Drysdale

Clark Armitage Moderates Panel On AI And Transfer Pricing At IBFD X C&D Planning For An AI Future In Cross-Border Tax Administration Conference

United States Tax

CD

Caplin & Drysdale

The 26th Annual U.S. And Europe Tax Practice Trends Conference - American Bar Association

United States Tax

BI

Buchanan Ingersoll & Rooney PC

Kirsten Burmester Explores APAs, Audits, MAPs And ICAPs At TP Minds Americas

United States Tax

CD

Caplin & Drysdale

Planning For An AI Future In Cross-Border Tax Administration

United States Tax

CD

Caplin & Drysdale

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