United States: Corporate Tax

April 2026 marks the 10th anniversary of the Panama Papers, one of the largest data leaks in history. The leak exposed how wealthy individuals and entities used offshore shell companies, trusts, and other structures for secrecy, tax planning, and potential IRS tax evasion.

A revocable living trust (sometimes called a revocable inter vivos trust) is a legal arrangement you create during your lifetime to hold legal title to your assets.

The reinstatement of downward attribution rules under Section 958(b)(4) and the introduction of Section 951B fundamentally alter how foreign entities are classified for U.S. tax purposes in 2026. These changes may reclassify certain foreign corporations, potentially increasing taxable income through Subpart F or Net CFC Tested Income inclusions while creating state-level compliance complexities. Organizations with cross-border operations must evaluate how these structural shifts affect their ownership chain