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
IRS Notice 2026-36 On Section 4960
On June 5, 2026, the Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (the “IRS”) issued Notice 2026-36 (the “Notice”), announcing their intent to issue proposed regulations under section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”). Code section 4960 imposes an excise tax on certain compensation paid to any “covered employee” of an applicable tax-exempt organization (an “ATEO”).
United States Tax
ST
Simpson Thacher & Bartlett
Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex
United States Tax
AO
A&O Shearman
Article
Florida Judge Determines Property Tax Amendment Ballot Language Defective; Attorney General To Revise
A Florida Circuit Court has ruled that the ballot language for Amendment 3, which proposes changes to homestead property tax exemptions, contains multiple defects that mislead voters about its true effects. The court found that the amendment's title and summary use emotional rhetoric, make improper conclusions, and fail to accurately describe how the measure would impact different classes of property owners and local government taxing authority. The Attorney General now has 10 days to prepare revised ballot
United States Tax
JW
Jones Walker
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Inheritance Tax

Article
New IRS Guidance Addresses Gift Tax Questions For Trump Accounts
The IRS and Treasury Department have issued new guidance addressing how contributions to Trump Accounts are treated for federal gift tax purposes, creating a safe harbor for qualifying donors. Revenue Procedure 2026-25 establishes specific requirements that allow certain contributions to be treated as completed gifts of a present interest, eligible for the annual gift tax exclusion without requiring Form 709 filing. Understanding these requirements is critical for donors to ensure compliance and avoid unnec
United States Tax
JW
Jones Walker
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Corporate Tax

Article
IRS Notice 2026-36 On Section 4960
On June 5, 2026, the Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (the “IRS”) issued Notice 2026-36 (the “Notice”), announcing their intent to issue proposed regulations under section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”). Code section 4960 imposes an excise tax on certain compensation paid to any “covered employee” of an applicable tax-exempt organization (an “ATEO”).
United States Tax
ST
Simpson Thacher & Bartlett
Article
ACA Affordability Threshold & Employer Shared Responsibility Penalties Increase For 2027
The IRS has announced significant changes to the Affordable Care Act affordability threshold and employer mandate penalties for 2027, raising the affordability percentage from 9.96% to 10.22% and increasing penalty amounts substantially. Employers subject to the ACA employer mandate must evaluate whether their current plan designs comply with these new thresholds to avoid potentially costly penalties. Understanding how these adjustments impact the three safe harbor calculations and penalty exposure is criti
United States Employment
CH
Calfee Halter & Griswold
Article
In Chester Chapter 9 Decision, Third Circuit Provides Guidance On Bankruptcy Treatment Of Municipal Revenue Bonds
The Third Circuit Court of Appeals has issued a pivotal ruling in Chester, Pennsylvania's chapter 9 bankruptcy case that examines when municipal revenue bonds maintain their secured status after a city files for bankruptcy protection. The decision analyzes three critical exceptions under Section 552(a) of the Bankruptcy Code that could preserve bondholders' liens on post-bankruptcy revenues, with implications for how municipal financing structures must be crafted to withstand bankruptcy proceedings.
United States Insolvency
HL
Hogan Lovells Cadwalader
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Capital Gains Tax

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