United States: Tax

Tax executives face material transactions that cannot wait for litigation to resolve interpretive uncertainty. This practical guide explores four critical IRS mechanisms—prefiling agreements, closing agreements, private letter rulings, and tax opinions—that provide varying levels of certainty for managing tax exposure before issues reach examination. Through conversations between controversy and transactional practitioners, discover when and how to deploy these tools along the continuum from inf

As Cadwalader approaches its merger with Hogan Lovells on July 1, the firm reflects on eight years of BrassTax publication, which has provided clear insights on major tax developments from the 2017 Tax Cuts and Jobs Act to cryptocurrency taxation and energy tax credits. The publication will integrate into the combined firm's platform over the summer, promising expanded coverage with a broader group of contributors in the fall.

One message stood out during our Tax Symposium 2026 session, Tax controversy: What’s hot and what’s not: The Internal Revenue Service (IRS) is becoming more strategic...

Washington State's estate tax rates are set to change again on July 1, 2026, bringing significant relief to estates of all sizes. The top rate will drop from 35% back to 20%, potentially saving estates hundreds of thousands of dollars compared to the current rate structure that has been in effect since July 2025.

The international landscape for estate and succession planning is being reshaped by unprecedented demographic shifts, evolving family structures, and the rise of digital wealth. As tens of trillions of dollars prepare to transfer between generations globally, legal practitioners must navigate an increasingly complex environment where traditional inheritance laws intersect with same-sex marriage recognition, assisted reproductive technologies, cryptocurrency holdings, and competing jurisdictional tax regimes

The IRS has issued Revenue Procedure 2026-25, offering welcome relief to individuals who contribute to “Trump accounts,” the new tax-favored savings vehicles for minors created under Section 530A...

The IRS has begun issuing Notice CP53E to taxpayers whose direct deposit information is missing or invalid, but some notices may have been sent in error. Fraudsters are exploiting this confusion by distributing convincing fake versions of the notice designed to steal personal and financial information. Tax professionals and taxpayers must carefully verify all IRS communications before providing sensitive banking details.

The One Big Beautiful Bill Act introduced Trump Accounts, a novel tax-advantaged savings vehicle for children under 18, with employer contribution provisions beginning in 2026. The Department of Labor's Technical Release 2026-02 addresses critical questions about whether these accounts and employer contribution programs fall under ERISA's regulatory framework. Employers must navigate specific conditions and distinctions between accounts benefiting employees versus their dependents to avoid unintended ERISA

In this episode of Splitting Heirs, partners Beth Shapiro Kaufman, National Chair of Private Client Services and Trusts and Estates Chair, and Kristin V. Taylor join host Warren K. Racusin to discuss the One Big Beautiful Bill through a tax and estates lens.

Greenberg Traurig shareholder Breen Schiller has submitted formal comments and testimony to Illinois tax authorities regarding proposed amendments to regulations governing addbacks for interest and intangible expenses in transactions with 80/20 companies. The comments address concerns about conduit exception narrowing, limitations on the "unreasonable" standard, and reliance on private letter rulings that may create administrability challenges for Illinois businesses.

Customs valuation determines the value of imported goods for assessing duties and taxes, with tariffs calculated as a percentage of declared entered value. Understanding transaction value methods, assists, royalties, Incoterms, and transfer pricing requirements is critical for multinational companies to avoid costly compliance errors and unexpected tariff liabilities.

One message stood out during our Tax Symposium 2026 session, Tax controversy: What’s hot and what’s not: The Internal Revenue Service (IRS) is becoming more strategic...