Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Pied-à-Terre Tax Confusion Continues: Staying The Course While Appeal Of Recent Order Is Pending
A New York Court of Claims judge has ordered substantial revisions to how New York City administers its Pied-à-Terre tax surcharge, canceling previously issued notices and shifting the burden of proof to the Department of Finance. The ruling requires individualized determinations before notices can be sent and eliminates the controversial exemption application process that had confused thousands of property owners. While the decision doesn't strike down the PAT law itself, it fundamentally restructures
United States Tax
HK
Holland & Knight
Article
IRS Targets “351 Conversion Transactions” And Flags Various Other ETF/Investment Fund Strategies As Possibly Abusive
The US Treasury and IRS have issued new guidance targeting ETF tax strategies, including the controversial '351 conversion transaction' that allows investors to defer taxation on appreciated securities. Revenue Ruling 2026-20 and Notice 2026-62 identify multiple strategies as potentially abusive, signaling increased scrutiny of tax deferral mechanisms used by exchange-traded funds and investment partnerships.
United States Tax
MB
Mayer Brown
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Tax Disputes

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Corporate Tax

Article
IRS Targets “351 Conversion Transactions” And Flags Various Other ETF/Investment Fund Strategies As Possibly Abusive
The US Treasury and IRS have issued new guidance targeting ETF tax strategies, including the controversial '351 conversion transaction' that allows investors to defer taxation on appreciated securities. Revenue Ruling 2026-20 and Notice 2026-62 identify multiple strategies as potentially abusive, signaling increased scrutiny of tax deferral mechanisms used by exchange-traded funds and investment partnerships.
United States Tax
MB
Mayer Brown
Article
The Second Circuit Opines On Self-Employment Taxes For “Limited Partners”
The Second Circuit Court of Appeals has weighed in on a critical tax question affecting partnership and LLC owners, affirming a narrow interpretation of who qualifies as a "limited" partner exempt from self-employment tax. This decision creates potential conflict with the Fifth Circuit's approach, raising questions about whether the Supreme Court will need to resolve the split and provide definitive guidance on this important issue for business owners.
United States Tax
N
Nossaman LLP
Article
How An S Corporation Election May Affect Financing And Exit
An S corporation election offers early-stage tax advantages but introduces significant constraints on venture financing, equity compensation structures, and exit strategies. Understanding five key restrictions—from shareholder eligibility rules to QSBS disqualification—helps founders determine whether S corporation status aligns with their growth trajectory and capital-raising plans.
United States Tax
GU
Gesmer Updegrove LLP
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Capital Gains Tax

Article
How An S Corporation Election May Affect Financing And Exit
An S corporation election offers early-stage tax advantages but introduces significant constraints on venture financing, equity compensation structures, and exit strategies. Understanding five key restrictions—from shareholder eligibility rules to QSBS disqualification—helps founders determine whether S corporation status aligns with their growth trajectory and capital-raising plans.
United States Tax
GU
Gesmer Updegrove LLP
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Withholding Tax

Article
Section 871(m) Phase-In Extended Two More Years
The Treasury Department and IRS have issued Notice 2026-61, extending the phase-in of Section 871(m) withholding regulations on dividend equivalent payments until 2029. This marks the sixth extension over more than a decade, affecting non-delta-one transactions, qualified derivative dealers, and the qualified securities lender regime, while Treasury officials indicate forthcoming regulations may replace or supplement the current framework.
United States Tax
MB
Mayer Brown
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Tax Authorities

Article
Pied-à-Terre Tax Confusion Continues: Staying The Course While Appeal Of Recent Order Is Pending
A New York Court of Claims judge has ordered substantial revisions to how New York City administers its Pied-à-Terre tax surcharge, canceling previously issued notices and shifting the burden of proof to the Department of Finance. The ruling requires individualized determinations before notices can be sent and eliminates the controversial exemption application process that had confused thousands of property owners. While the decision doesn't strike down the PAT law itself, it fundamentally restructures
United States Tax
HK
Holland & Knight
Article
IRS Targets “351 Conversion Transactions” And Flags Various Other ETF/Investment Fund Strategies As Possibly Abusive
The US Treasury and IRS have issued new guidance targeting ETF tax strategies, including the controversial '351 conversion transaction' that allows investors to defer taxation on appreciated securities. Revenue Ruling 2026-20 and Notice 2026-62 identify multiple strategies as potentially abusive, signaling increased scrutiny of tax deferral mechanisms used by exchange-traded funds and investment partnerships.
United States Tax
MB
Mayer Brown
See more

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