Tax Law and International Tax Law

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.

The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.

Discover how artificial intelligence is transforming tax law and intellectual property, while examining critical issues of tax rates and wealth inequality in modern America. Professor Jeremy Bearer-Friend from George Washington University Law School shares expert insights on these evolving challenges in the tax landscape.

For Canadian and other non-U.S. sellers of U.S. real estate, the FIRPTA withholding regime has historically meant waiting months or even years to recover excess tax withholdings. Recent improvements in IRS processing times are making Form 8288-B withholding certificate applications an increasingly effective tool for accelerating the return of substantial funds.

The September 2026 Wealth Management Update covers critical developments in estate planning, including updated AFRs and Section 7520 rates, comprehensive analysis of NYC's new pied-à-terre tax...

Georgia's 2026 legislative session brought significant state tax changes, including updated IRC conformity rules that deliberately diverge from federal law in key areas. While the state adopted many provisions from the federal One Big Beautiful Bill Act, it declined to follow federal treatment of tips, overtime pay, SALT deductions, and bonus depreciation—creating important compliance considerations for businesses operating in the state.

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.

The Maryland Tax Court struck down the state's digital advertising tax on multiple constitutional grounds, potentially establishing a precedent for challenging similar state taxes targeting the digital economy. The decisions address fundamental questions about how states can tax digital services without violating federal law and constitutional protections.

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.

The One Big Beautiful Bill Act has fundamentally transformed the Qualified Small Business Stock exclusion under Section 1202, creating unprecedented tax-saving opportunities for entrepreneurs and investors.

When adding a partner or outside investor to your business, understanding the tax implications is crucial for both personal and business finances. This comprehensive guide explores entity structure considerations...

The One Big Beautiful Bill Act has fundamentally transformed Section 1202's qualified small business stock (QSBS) tax benefits, introducing tiered holding periods that allow partial capital gains exclusions...