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
IRS Proposes New Racial Nondiscrimination Regulations For Tax-exempt Private Schools
The US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.
United States Tax
SR
McDermott Will & Schulte
Article
New York’s Revised P.L. 86-272 Regulation Survives Judicial Appeal
A New York appellate court recently ruled on the state's revised P.L. 86-272 regulation, determining it is not facially preempted by federal law but cannot be applied retroactively before December 2023. The decision leaves open the possibility of future taxpayer-specific challenges while providing clarity on how internet-based business activities may affect state tax obligations for out-of-state sellers.
United States Tax
MG
MGO CPA LLP
Article
What Changed With USPS Postmarks And Why Taxpayers Should Care
With tax season underway, a critical change to USPS postmarking procedures could put taxpayers at risk of unintended late filings. As of December 24, 2025, mail is now postmarked based on when it's processed at a postal facility rather than when it's dropped off, potentially creating discrepancies between actual mailing dates and official postmarks. This shift has significant implications for anyone relying on postmark dates as proof of timely filing for federal and state tax returns.
United States Tax
Wagner Tax Law
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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
New York’s Revised P.L. 86-272 Regulation Survives Judicial Appeal
A New York appellate court recently ruled on the state's revised P.L. 86-272 regulation, determining it is not facially preempted by federal law but cannot be applied retroactively before December 2023. The decision leaves open the possibility of future taxpayer-specific challenges while providing clarity on how internet-based business activities may affect state tax obligations for out-of-state sellers.
United States Tax
MG
MGO CPA LLP
Article
What Changed With USPS Postmarks And Why Taxpayers Should Care
With tax season underway, a critical change to USPS postmarking procedures could put taxpayers at risk of unintended late filings. As of December 24, 2025, mail is now postmarked based on when it's processed at a postal facility rather than when it's dropped off, potentially creating discrepancies between actual mailing dates and official postmarks. This shift has significant implications for anyone relying on postmark dates as proof of timely filing for federal and state tax returns.
United States Tax
Wagner Tax Law
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Capital Gains Tax

Article
Delaware And New York Courts Reject Securities Act Challenges To GAAP-Compliant Mutual Fund NAV Accounting
Courts in Delaware and New York recently have dismissed with prejudice parallel putative class actions challenging mutual fund NAV accounting practices. The decisions are important victories for advisers to registered funds. Both cases asserted claims under the Securities Act of 1933, alleging that equity mutual funds misstated NAV by treating accrued dividends and realized capital gains as assets rather than liabilities.
United States Finance
ST
Simpson Thacher & Bartlett
Article
Existing Opportunity Zone Investors Must Evaluate Planning Opportunities Before Dec. 31, 2026
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.
United States Tax
JM
Jeffer Mangels & Mitchell LLP
Article
GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation
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.
United States Tax
RS
Rotfleisch & Samulovitch P.C.
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Property Taxes

Article
Cleared For Takeoff? Understanding California's Aircraft Personal Property Tax
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.
United States Tax
HK
Holland & Knight
Article
Florida Homestead Exemption Proposal Could Reshape Single-Family Development
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.
United States Real Estate
HK
Holland & Knight
Article
New York City’s “pied-à-terre Tax”: What Owners Need To Know Now
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.
United States Tax
AO
A&O Shearman
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