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
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 Disputes

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Capital Gains Tax

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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Tax Authorities

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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Sales Taxes: VAT, GST

Article
City Of New Orleans Announces Sales Tax Amnesty Program
The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.
United States Tax
LL
Liskow & Lewis
Article
CDFTA Addresses Stakeholder Questions on California’s SB 122 Software and SaaS Tax
California's Department of Tax and Fee Administration held its second meeting to discuss emergency regulations implementing Senate Bill 122, which will extend sales and use tax to prewritten software and SaaS starting January 1, 2027. Stakeholders raised critical questions about sourcing rules, contract transitions, multistate deployment, and administrative provisions that remain unresolved as the implementation date approaches.
United States Tax
GT
Greenberg Traurig, LLP
Article
Coming Attractions: California Previews Rules On SaaS And Digital Products Tax
The California Department of Tax and Fee Administration (CDTFA) has released draft regulatory language it is considering proposing, offering its first comprehensive view of how it may administer Senate Bill 122, California's expansion of sales and use tax to software as a service (SaaS) and certain digital products beginning January 1, 2027. CDTFA has not yet formally proposed these regulations through the emergency rulemaking process.
United States Tax
HK
Holland & Knight
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Inheritance Tax

Article
A $13 Million Reminder: Domicile Planning Is More Than Paperwork
A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.
United States Tax
WD
Wiggin & Dana
Article
A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act
California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United States Tax
WL
Withers LLP
Article
FASB’s New Fair Value Standard May Bolster Marketability Discounts In Estate Planning
The Financial Accounting Standards Board issued Accounting Standards Update 2026-03, Fair Value Measurement (Topic 820): Investment Companies with Equity Securities Subject to Contractual Sale Restrictions, on September 9, 2026. While the update is aimed at investment company accounting, it could benefit estate planners and valuation professionals who regularly defend marketability discounts on closely held and restricted stock.
United States Tax
LL
Liskow & Lewis
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