United States: Tax

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...

Global families investing in U.S. real estate face critical tax structuring decisions at acquisition that can either preserve wealth or create decades of avoidable exposure. How should international investors structure their U.S. property purchases to minimize estate tax, FIRPTA obligations, and state tax compliance issues before closing the deal?

The US Treasury and IRS have issued new proposed regulations modifying the applicability dates for Section 892 rules affecting foreign government investors, providing crucial transitional relief and grandfathering protection...

Portability of estate and gift tax enables a surviving spouse to inherit any unused portion of their deceased spouse's federal estate and gift tax exemption, potentially doubling the exemption amount. While this powerful mechanism can help married couples preserve unused tax exemptions and minimize transfer tax liability, it is frequently misunderstood, underutilized, or improperly elected. Understanding the statutory framework, mechanics...

Max Schneberger discusses how recent changes from the One Big Beautiful Bill Act (OBBBA) have created expanded trust planning opportunities for individuals and families in the July issue of Lake Country Living.

Recent tax developments include New York City's new property tax surcharge on high-value pied-à-terre homes and potential changes to IRS Form 1040 that would require disclosure of citizenship status and dual citizenship. These policy shifts reflect growing efforts to address tax equity in luxury real estate markets and enhance transparency in tax reporting for individuals with complex international ties.

Artificial intelligence has moved to the center of how the Internal Revenue Service selects tax returns for audit, detects tax fraud, and administers the U.S. tax system.

The Tenth Circuit's Liberty Global decision addresses a fundamental question about when the codified economic substance doctrine applies to tax transactions.

Employers continue to receive pitches for wellness and medical indemnity programs promising significant payroll tax savings, but recent IRS guidance makes clear these arrangements...

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...

African governments are rapidly modernising their approach to tax and customs in the resources sector. Fiscal tools, tighter compliance frameworks and procedural reforms are reshaping investment and operational conditions across the continent.

In May, the I.R.S. announced a settlement offer for partnerships involved in disputes concerning "syndicated conservation easements." The key features of the offer include a 10% penalty for gross valuation misstatement, instead of a 40% penalty, and no upfront payment required.