Tax Law and International Tax Law

The IRS has issued Notice 2026-40 providing transition guidance for investors who deferred capital gains under the original Opportunity Zone program. While December 31, 2026 remains the mandatory recognition date for deferred gains, the guidance reveals a potential planning opportunity that may allow certain investors to continue deferring gains under the new Opportunity Zone regime through strategic pre-year-end transactions.

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.

Early decisions about a start-up's legal structure can dramatically affect tax outcomes and financial returns as the company grows and reaches liquidity events. Understanding the Qualified Small Business Stock (QSBS) exemption and implementing proper structuring from the outset can significantly enhance returns for both founders and investors.

California law treats aircraft as taxable tangible personal property subject to annual appraisal and local property taxation. With counties like Los Angeles increasing enforcement efforts, aircraft owners face significant compliance obligations, potential penalties, and a complex valuation process. Understanding the state's filing requirements, exemptions, and critical deadlines is essential for anyone who owns or operates aircraft regularly based in California.

Florida's proposed constitutional amendment to expand homestead exemptions could fundamentally reshape the state's residential real estate market by altering buyer incentives and development economics. The measure, set for a November 2026 ballot, may eliminate non-school property taxes for up to 90 percent of primary households, creating ripple effects across land values, municipal revenues, and construction feasibility that extend far beyond simple tax relief.

New York City has begun notifying owners of high-value residential properties about a newly enacted annual surcharge on units not used as primary residences. While receipt of a notice doesn't automatically mean payment is required, it does impose response obligations on owners of second homes, investment properties, and trust-held residences. The surcharge faces active litigation, with courts currently permitting collection to proceed despite ongoing legal challenges.

The Congressional Budget Office (CBO) recently reported that under current federal income tax rules, employer-sponsored health plans could receive trillions in subsidies over the next decade. CBO analysts prepared the 2026 report with staff analysts from the congressional Joint Committee on Taxation (JCT).

The IRS has released new guidance on the Section 45Z Clean Fuels Production Tax Credit, introducing significant changes that affect how American farmers, ranchers, and fuel producers can access benefits from the domestic biofuels market. Notice 2026-53 provides updated emissions rate tables and addresses critical modifications mandated by the Working Families Tax Cuts, including special provisions for manure-derived fuels and regenerative agricultural practices.

US corporate executives relocating abroad face complex tax obligations that extend beyond borders. From worldwide income taxation and foreign tax credits to state residency issues and potential expatriation taxes, understanding these planning areas is essential for avoiding costly penalties and optimizing your tax position.

A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.

The Financial Accounting Standards Board issued Accounting Standards Update 2026-03, Fair Value Measurement (Topic 820): Investment Companies with Equity Securities Subject to Contractual Sale Restrictions, on September 9, 2026. While the update is aimed at investment company accounting, it could benefit estate planners and valuation professionals who regularly defend marketability discounts on closely held and restricted stock.