United States: Tax

Subscribe
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
US Federal Court Considers The Implications For Canadian Exempt Organizations Earning US Source Income Through An Intermediary Vehicle
The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment
United States Tax
TL
Torys LLP
See more

Related Country Guides

TD
Tax Disputes

Highlighted Content

Tax Treaties

Article
US Federal Court Considers The Implications For Canadian Exempt Organizations Earning US Source Income Through An Intermediary Vehicle
The US Court of Federal Claims recently addressed a critical question for Canadian exempt organizations earning US-source income: can they rely on fiscal transparency rules to claim treaty benefits through investment vehicles? The court's ruling in The South Saskatchewan Community Foundation Inc. v. United States examines when charitable organizations may look through intermediary entities to access tax exemptions under the US-Canada tax treaty, with significant implications for cross-border investment
United States Tax
TL
Torys LLP
Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.
United States Tax
HL
Hogan Lovells Cadwalader
See more

Inheritance Tax

Article
The Unexpected Tax Consequences Of Ending A QTIP Trust Early
Qualified terminable interest property (“QTIP”) trusts are a familiar estate-planning tool. Under a QTIP trust, a spouse receives the benefit of trust assets during life, with the remainder passing to children or other beneficiaries after the spouse’s death. No transfer tax is payable on the creation of the QTIP trust due to the availability of the marital deduction but the trust assets will be subject to estate tax on the spouse’s death.
United States Tax
FF
Farrell Fritz, P.C.
Article
Can You Change An Irrevocable Trust In New Jersey?
In New Jersey, irrevocable trusts can sometimes be modified through a process called decanting, which allows trustees to transfer assets into a new trust with different terms. Understanding when decanting is available under common law, what discretion trustees must have, and what tax and fiduciary risks are involved is essential for anyone administering or benefiting from an irrevocable trust in the state.
United States Tax
SH
Scarinci Hollenbeck LLC
See more

Income Tax

Article
The Unexpected Tax Consequences Of Ending A QTIP Trust Early
Qualified terminable interest property (“QTIP”) trusts are a familiar estate-planning tool. Under a QTIP trust, a spouse receives the benefit of trust assets during life, with the remainder passing to children or other beneficiaries after the spouse’s death. No transfer tax is payable on the creation of the QTIP trust due to the availability of the marital deduction but the trust assets will be subject to estate tax on the spouse’s death.
United States Tax
FF
Farrell Fritz, P.C.
See more

Transfer Pricing

Article
IRS Issues Proposed Regulations Excluding Income From Certain Property Sales From FDDEI Under Section 250(b)(3)(A)(i)(VII)
The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.
United States Tax
AO
A&O Shearman
Article
Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge
The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.
United States Tax
SR
McDermott Will & Schulte
Article
Daniel Keller Hosted The American Bar Association’s People In Tax Podcast Episode, “Bonus Episode: Professor Jeremy Bearer-Friend."
Discover how artificial intelligence is transforming tax law and intellectual property, while examining critical issues of tax rates and wealth inequality in modern America. Professor Jeremy Bearer-Friend from George Washington University Law School shares expert insights on these evolving challenges in the tax landscape.
United States Tax
DW
Dickinson Wright PLLC
See more

Latest Videos

See more