Tax Law and International Tax Law

In this episode of Splitting Heirs, host Warren K. Racusin invites Lowenstein partner Michael N. Gooen and Dr. Paul Hokemeyer, the founding principal of Drayson Mews

Ultra-high-net-worth individuals and families face a valuation environment that is far more complex than simply determining the worth of an asset. In the context of trust, gift, and estate tax planning, valuation becomes a foundational discipline that affects wealth transfer strategy, tax efficiency, compliance, and long-term family outcomes.

Massachusetts quietly amended its estate tax statute last summer. This amendment significantly changes how the tax is calculated for non-resident decedents owning Massachusetts real estate.

Employer-issued recourse promissory notes allow employees to acquire equity without immediate cash outlay, but they create personal liability regardless of stock performance. This analysis examines the strategic advantages, tax implications, and significant risks that both companies and employees face when using this compensation structure.

The IRS has issued final regulations under Treasury Decision 10048 that fundamentally restructure the reporting timeline for partnerships when a partner sells their interest, eliminating a January 31 deadline that practitioners found...

Section 1202 of the Internal Revenue Code offers substantial tax benefits for qualified small business stock (QSBS) holders, allowing exclusion of gains up to $10 million or more per taxpayer. Strategic gifting of QSBS shares to family members, trusts, and other entities can multiply these exclusions, potentially sheltering tens of millions in capital gains from federal taxation while navigating complex timing, gift tax, and trust structure considerations.

A sophisticated tax planning technique for take-private transactions demonstrates how companies can leverage built-in losses from one subsidiary to offset gains from another, potentially achieving stepped-up tax basis at no incremental cash cost.

Delaware Statutory Trusts (DSTs) continue to grow in popularity as a passive real estate investment vehicle — especially for investors seeking a streamlined option in a 1031 exchange.

In 2026, the federal tax treatment of export income undergoes a structural shift as FDDEI replaces FDII, eliminating the qualified business asset investment limitation and revising expense allocation rules.

Cyber‑enabled cargo theft is a modern form of freight theft in which criminals use digital impersonation, stolen credentials and system manipulation to fraudulently obtain cargo...

The Autumn Budget contained a range of pensions-related announcements with implications for employers and trustees of all occupational pension schemes.

The Chancellor has today announced her highly anticipated autumn Budget.