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Article
IRS Notice 2026-36 On Section 4960
On June 5, 2026, the Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (the “IRS”) issued Notice 2026-36 (the “Notice”), announcing their intent to issue proposed regulations under section 4960 of the Internal Revenue Code of 1986, as amended (the “Code”). Code section 4960 imposes an excise tax on certain compensation paid to any “covered employee” of an applicable tax-exempt organization (an “ATEO”).
United States Tax
ST
Simpson Thacher & Bartlett
Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex
United States Tax
AO
A&O Shearman
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Tax Treaties

Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex
United States Tax
AO
A&O Shearman
Article
Federal Court Vacates IRS Notice 2025-42, Restoring Five Percent Safe Harbor For “Beginning Of Construction” On Wind And Solar Projects
A federal court has vacated IRS Notice 2025-42, which eliminated the Five Percent Safe Harbor for establishing "beginning of construction" for wind and solar projects seeking federal clean energy tax credits. With less than a month before the July 4, 2026 statutory deadline and an expected appeal, developers face critical decisions about whether to rely on the restored safe harbor or continue with existing compliance strategies under uncertainty.
United States Tax
FH
Foley Hoag LLP
Article
Permanent Establishments Series #3: Expanding Into Europe Through A Dutch BV - New York Office Snippet
When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.
United States Tax
LL
Loyens & Loeff
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Inheritance Tax

Article
New IRS Guidance Addresses Gift Tax Questions For Trump Accounts
The IRS and Treasury Department have issued new guidance addressing how contributions to Trump Accounts are treated for federal gift tax purposes, creating a safe harbor for qualifying donors. Revenue Procedure 2026-25 establishes specific requirements that allow certain contributions to be treated as completed gifts of a present interest, eligible for the annual gift tax exclusion without requiring Form 709 filing. Understanding these requirements is critical for donors to ensure compliance and avoid unnec
United States Tax
JW
Jones Walker
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Income Tax

Article
IRS Quietly Ends The Delinquent FBAR Submission Procedures: What American Taxpayers With Unreported Foreign Accounts Should Do Now
No IRS relief program is permanent, and the agency rarely gives taxpayers advance warning before one disappears. On July 1, 2026, that lesson repeated itself: the IRS quietly eliminated the Delinquent FBAR Submission Procedures, a program that for over a decade had let taxpayers who missed a Foreign Bank Account Report, but had otherwise paid every dollar of tax they owed, catch up without penalty. 
United States Tax
RS
Rotfleisch & Samulovitch P.C.
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Transfer Pricing

Article
Proposed Regulations Address CFC Taxable Year And Partial FTC Disallowance On PTEP Distributions
The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex
United States Tax
AO
A&O Shearman
Article
Are AI And ESG Redefining Transfer Pricing Roles In Banking
Banking groups are under pressure to transform their operating models due to digitalization, changing customer expectations, and heightened ESG requirements. As AI platforms, data governance, and ESG frameworks reshape value creation and risk allocation, the traditional transfer pricing roles and cost-based remuneration models in banking may need fundamental reassessment to reflect evolving business realities.
United States Tax
N
NERA
Article
Permanent Establishments Series #3: Expanding Into Europe Through A Dutch BV - New York Office Snippet
When US multinational enterprises expand into Europe through a Dutch BV general European company, hiring employees in other jurisdictions before establishing local subsidiaries can create unexpected permanent establishment risks. The tax implications depend heavily on employee activities, decision-making authority, and home-office arrangements, requiring careful assessment before making local hires.
United States Tax
LL
Loyens & Loeff
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