Tax Law and International Tax Law

New York City's new pied-à-terre surcharge introduces a "renovation gap" that may unexpectedly impact property owners during major construction projects. Partners Alexandra Wald and Nicholas Kaiser analyze why owners of properties that cannot be legally occupied during renovations may still face the surcharge, and what stakeholders should consider to navigate this complex issue.

This amendment increases the homestead exemption, for all non-school taxes, to $150,000 in 2027, and $250,000 in 2028, and adjusts for inflation thereafter. It requires the legislature to prescribe a uniform procedure for counties and municipalities, for their respective levies, to increase the homestead exemption up to full assessed value, and allows special districts, subject to referendum approval, to do the same.

The U.S. Supreme Court's decision in Pung v. Isabella County addresses whether former property owners are entitled to fair market value or only surplus proceeds when their property is sold at a tax foreclosure auction. This ruling clarifies the constitutional measure of compensation following tax sales and has significant implications for counties, municipalities, tax-lien investors, and delinquent taxpayers navigating the balance between tax collection and property rights.

The Treasury Department and IRS have issued Notice 2026-50, expanding the safe harbor for section 45Q carbon capture tax credits by extending Subpart RR reporting requirements to enhanced oil recovery projects and establishing a transition period tied to future guidance. This interim relief addresses critical gaps in the carbon capture regulatory framework while Treasury seeks public comment on permanent alternatives to EPA's Greenhouse Gas Reporting Program requirements.

This roundup examines critical IRS developments spanning executive nominations, procedural relief mechanisms, and landmark court decisions that reshape tax collection enforcement and whistleblower award determinations. From supervisory approval requirements for penalty assessments to jurisdictional questions in Collection Due Process proceedings, these developments carry significant implications for taxpayers navigating federal tax controversies and compliance obligations.

For the better part of a decade, every estate planning conversation my colleagues had with a high-net-worth family started with the same clock: the 2017 Tax Cuts and Jobs Act exemption was set to sunset at the end of 2025, and attorneys, advisors and trustees were racing to get gift programs, spousal lifetime access trusts (SLATs) and irrevocable trusts funded before it reverted to pre-2017 levels.

The North Carolina Department of Revenue has announced the repeal of a significant sales and use tax exemption for electricity purchased by Certified Datacenters, effective August 2026. This change will require datacenter operators to pay combined general sales and use tax rates on electricity purchases and comply with new quarterly reporting requirements, while other datacenter-related exemptions remain intact.

North Carolina has introduced a new tax on peer-to-peer vehicle sharing platforms like Turo and Zipcar, effective October 1, 2026. The tax rates vary from 3% to 8% depending on the rental type, with providers required to register with the state Department of Revenue and collect taxes on their gross receipts. Understanding these new compliance requirements is essential for peer-to-peer vehicle sharing businesses operating in North Carolina.

North Carolina's Department of Revenue has issued new guidance consolidating sales and use tax refund caps for nonprofit hospital systems and their affiliates, fundamentally changing how multi-entity healthcare organizations claim tax refunds. The directive introduces aggregation rules that treat hospital systems as single entities for refund purposes, with prorated caps for the current fiscal year. Healthcare organizations must now coordinate refund claims across their entire system and reassess the financ

The IRS has introduced a new Automatic Exemption from Penalty program while a federal court struck down key GILTI regulations in a significant post-Loper Bright decision. The Treasury and IRS also finalized guidance on life insurance contract transactions and updated various energy-related tax credits and reporting requirements.

The IRS has finalized new Section 987 regulations that fundamentally change how businesses with foreign operations report currency gains and losses, with compliance beginning for the 2025 tax year. These regulations require taxpayers to calculate cumulative foreign currency positions dating back to 2006 or entity inception, while IRS Notice 2026-17 offers a simplified election that may reduce administrative burden for qualifying businesses. Understanding these changes now is critical to avoid penalties, ens

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...