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
California Office Of Tax Appeals Rejects Unitary Business Treatment For Gain From Sale Of Company Division
The California Office of Tax Appeals examined whether a beverage distribution division operated as part of a unitary business with a taxpayer's other divisions, applying both the three unities test and the contribution and dependency test. The decision addresses critical questions about apportionability of income from asset sales and whether the tax benefit rule requires recovery of previously claimed deductions when operations are determined to be non-unitary.
United States Tax
GT
Greenberg Traurig, LLP
Article
IRS Proposes New Rules For Private Schools With Race-Based Policies
The Department of the Treasury and IRS have proposed regulations that would eliminate tax-exempt status for private schools maintaining race-based policies in admissions, scholarships, or programs—regardless of remedial or diversity objectives. The rule would affect approximately 18,000 tax-exempt schools, 750,000 students, and outstanding tax-exempt bonds, fundamentally reshaping how educational institutions approach diversity initiatives and donor-restricted scholarships.
United States Tax
M
Mintz
Article
IRS Finalizes Rules On The New Car Loan Interest Deduction
The Treasury Department and IRS issued final regulations implementing the new deduction for qualified passenger vehicle loan interest (QPVLI), a temporary benefit created by the One, Big, Beautiful Bill Act (OBBBA) that allows individuals to deduct up to $10,000 of interest paid on certain auto loans, even if they do not itemize deductions. The final rules largely adopt the proposed regulations issued in January 2026 but include clarifications in response to public comments received by the Treasury Department.
United States Tax
LL
Liskow & Lewis
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Tax Disputes

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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
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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
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Sales Taxes: VAT, GST

Article
States Begin Addressing Sales Tax Effects Of Cessation Of Penny Production
Following the U.S. Mint's decision to stop producing pennies, states across the nation are issuing new guidance on how retailers should handle cash transaction rounding. While most states require sales tax to be calculated on the original sales price before rounding occurs, the specific rounding methods and compliance requirements vary significantly by jurisdiction, creating a complex landscape for multistate retailers to navigate.
United States Tax
MG
MGO CPA LLP
Article
Hearing On Proposed Amendment To LAC 61:I.4372 — Sales & Use Tax Obligations Of Persons Constructing, Repairing Or Altering Immovable Property
The Louisiana Department of Revenue has proposed amendments to its regulation governing sales and use tax responsibilities for contractors and their customers, generating significant public interest. A public hearing has been scheduled to address the substantial volume of comments received regarding these proposed changes.
United States Tax
JW
Jones Walker
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Income Tax

Article
IRS Finalizes Rules On The New Car Loan Interest Deduction
The Treasury Department and IRS issued final regulations implementing the new deduction for qualified passenger vehicle loan interest (QPVLI), a temporary benefit created by the One, Big, Beautiful Bill Act (OBBBA) that allows individuals to deduct up to $10,000 of interest paid on certain auto loans, even if they do not itemize deductions. The final rules largely adopt the proposed regulations issued in January 2026 but include clarifications in response to public comments received by the Treasury Department.
United States Tax
LL
Liskow & Lewis
Article
Latest Tax Updates: Trump Account Investment Rules, Subpart F Proration, And Conservation Easement Enforcement
The IRS and Treasury Department issued significant guidance in late August 2026 on Trump Accounts, CFC income calculations, and conservation easement enforcement, while federal appellate courts delivered pivotal rulings on the limited partner exception to self-employment tax and the Anti-Injunction Act's scope. These developments reshape tax compliance strategies for individuals, corporations, and partnerships navigating charitable deductions, international income allocation, and procedural challenges.
United States Tax
SR
McDermott Will & Schulte
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