Tax Law and International Tax Law

California law treats aircraft as taxable tangible personal property subject to annual appraisal and local property taxation. With counties like Los Angeles increasing enforcement efforts, aircraft owners face significant compliance obligations, potential penalties, and a complex valuation process. Understanding the state's filing requirements, exemptions, and critical deadlines is essential for anyone who owns or operates aircraft regularly based in California.

Florida's proposed constitutional amendment to expand homestead exemptions could fundamentally reshape the state's residential real estate market by altering buyer incentives and development economics. The measure, set for a November 2026 ballot, may eliminate non-school property taxes for up to 90 percent of primary households, creating ripple effects across land values, municipal revenues, and construction feasibility that extend far beyond simple tax relief.

New York City has begun notifying owners of high-value residential properties about a newly enacted annual surcharge on units not used as primary residences. While receipt of a notice doesn't automatically mean payment is required, it does impose response obligations on owners of second homes, investment properties, and trust-held residences. The surcharge faces active litigation, with courts currently permitting collection to proceed despite ongoing legal challenges.

The OECD's proposed revision of Chapter VII of the Transfer Pricing Guidelines aims to clarify the framework for intra-group services, with the benefit test emerging as the central analytical principle.

The IRS has intensified scrutiny of partnership basis-shifting transactions that manipulate inside and outside basis rules to generate tax savings. While recent regulations were withdrawn under the Trump Administration, the agency maintains its position through Rev. Rul. 2024-14, which identifies three transaction types that fail the economic substance doctrine.

The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.

Jennifer brings a distinguished background spanning corporate law, bankruptcy, criminal prosecution, and sophisticated trusts and estates matters to her new role. Her unique combination of courtroom experience, government service, and private practice expertise positions her to deliver comprehensive fiduciary and estate planning solutions. Beyond legal practice, she has pioneered academic programs in trust management and earned national recognition for making complex tax and fiduciary concepts accessible to

Foreign owners of single-member U.S. limited liability companies often assume their entities are completely disregarded for tax purposes, but since 2017, these structures face significant reporting obligations...

The OECD's proposed revision of Chapter VII of the Transfer Pricing Guidelines aims to clarify the framework for intra-group services, with the benefit test emerging as the central analytical principle.

The Department of Justice's August 13, 2026, memorandum establishing enforcement priorities for the newly reconstituted National Fraud Enforcement Division identifies "internal revenue" as a principal enforcement area and signals that DOJ intends to deploy broader, more technologically sophisticated tools to detect and prosecute tax fraud. For companies across all industries...

Foreign owners of single-member U.S. limited liability companies often assume their entities are completely disregarded for tax purposes, but since 2017, these structures face significant reporting obligations...

The Treasury Department and IRS have issued Notice 2026-61, extending the phase-in of Section 871(m) withholding regulations on dividend equivalent payments until 2029. This marks the sixth extension over more than a decade, affecting non-delta-one transactions, qualified derivative dealers, and the qualified securities lender regime, while Treasury officials indicate forthcoming regulations may replace or supplement the current framework.