United States: Tax

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

The IRS recently released Revenue Procedure 2026-25, which establishes a transfer tax safe harbor for certain contributions to Trump Accounts.

Although IRS enforcement efforts have evolved, estate and gift tax examinations remain an area of focus, particularly for high value estates and sophisticated wealth transfer transactions.

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

S corporation shareholders who elected to defer the Section 965 transition tax under the Tax Cuts and Jobs Act face ongoing compliance obligations and potential acceleration risks. Understanding the strict filing deadlines, triggering events, and annual reporting requirements is essential to avoid unexpected tax liabilities and costly penalties that can arise from routine business transactions or estate planning activities.

Jared Walczak of the Tax Foundation joins the GeTtin' SALTy podcast to examine the growing movement to eliminate real property taxes in the United States, using Ohio as a detailed case study. The discussion explores the fiscal challenges of replacing property tax revenue, the impact on local government accountability, and alternative policy solutions like levy limits and circuit breaker programs that address taxpayer concerns without dismantling the property tax system.

The forms support the final Section 987 regulations issued in December 2024, which provide guidance for determining taxable income, loss, and earnings and profits for qualified business units (QBUs) that use a different functional currency than their owners. The regulations apply to tax years beginning in 2025.

Something labeled “defective” usually does not work properly. The intentionally “defective” grantor trust, or “IDGT,” however, is a proven workhorse for tax-efficient business succession planning. A carefully planned and executed IDGT transaction enables business owners to transfer significant value in trust for the benefit of younger generations, with remarkable tax efficiency, while retaining control over the business. Two seemingly contradictory tax attributes of the IDGT underlie its tax efficiency.

Banking groups are under pressure to transform their operating models due to digitalization, changing customer expectations, and heightened ESG requirements. As AI platforms, data governance, and ESG frameworks reshape value creation and risk allocation, the traditional transfer pricing roles and cost-based remuneration models in banking may need fundamental reassessment to reflect evolving business realities.

When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.

On the morning of 21 July 2026 at a meeting of the Wall Street Tax Association, officials from the Internal Revenue Service (IRS) and Department of Treasury (Treasury) joined in a discussion with income tax...