United States: Tax

Indirect tax obligations are evolving rapidly as governments modernize their rules for the digital economy. If your organization is working across borders...

The IRS has reversed its 2024 policy and will now issue private letter rulings on significant issues in corporate reorganizations and spin-offs, allowing taxpayers to request guidance on discrete legal matters rather than entire transaction structures.

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

Massachusetts quietly amended its estate tax statute last summer. This amendment significantly changes how the tax is calculated for non-resident decedents owning Massachusetts real estate.

With a federal estate tax rate of 40%, estate planning conversations often start and stop with the relatively high federal exemption (currently $15 million for individuals and $30 million for married couples).

A revocable living trust (sometimes called a revocable inter vivos trust) is a legal arrangement you create during your lifetime to hold legal title to your assets.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Taken together, these developments reinforce that tax changes are not occurring in isolation. As governments continue to revise their tax frameworks, businesses and individuals alike are seeking coordinated cross-border advice to assess both risk and opportunity.

April 2026 marks the 10th anniversary of the Panama Papers, one of the largest data leaks in history. The leak exposed how wealthy individuals and entities used offshore shell companies, trusts, and other structures for secrecy, tax planning, and potential IRS tax evasion.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Transfer pricing complexities emerge as artificial intelligence systems increasingly rely on vast training datasets, raising critical questions about how multinational corporations should value and allocate these intangible assets across jurisdictions. The intersection of AI development and international tax law presents novel challenges for determining arm's length pricing when data crosses borders within corporate structures.

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.