United States: Corporate Tax

Georgia's 2026 legislative session brought significant state tax changes, including updated IRC conformity rules that deliberately diverge from federal law in key areas. While the state adopted many provisions from the federal One Big Beautiful Bill Act, it declined to follow federal treatment of tips, overtime pay, SALT deductions, and bonus depreciation—creating important compliance considerations for businesses operating in the state.

The Treasury Department and IRS have introduced a new standardized framework for direct rollovers between retirement plans and IRAs, featuring a five-step process with sample forms designed to simplify what has historically been a fragmented and paper-heavy system. While adoption remains voluntary and no formal safe harbor exists yet, this initiative addresses longstanding inefficiencies in rollover procedures that have caused participant confusion and delays.

The IRS and Treasury have issued proposed regulations limiting Trump Account investments during the growth period to low-cost, passively managed index funds and ETFs tracking broad-based US equity indices, while establishing strict investment-selection, monitoring, and correction requirements for trustees.

Organizations preparing to scale through hiring, market expansion, or capital investments must establish strong financial controls and tax processes to support sustainable growth. This comprehensive checklist outlines critical steps to strengthen payroll infrastructure, map multi-state tax exposure, align capital expenditures with tax strategy, enhance internal controls, and integrate proactive tax planning into growth initiatives.

The Fifth Circuit Court of Appeals has modified its stance on self-employment taxes for pass-through entity owners, moving from a simple liability-based test to a more nuanced "significance" test that examines an owner's involvement in business operations. This shift creates uncertainty for LLC and partnership owners who must now evaluate whether their management role is "significant" enough to trigger self-employment tax obligations, while traditional limited partners may still find safe harbor from these

A recent decision from the United States District Court for the Southern District of Florida offers a cautionary tale for estate planners who rely on Qualified Personal Residence Trusts (QPRTs) and the interplay between state homestead protections and federal estate tax inclusion rules.

The IRS has issued new guidance requiring foreign vessel owners operating under the Jones Act waiver to report income from U.S. interstate voyages as domestic source income subject to federal taxation. This marks a significant departure from the typical treatment of international shipping income, which often benefits from exclusions and treaty exemptions, and creates unexpected tax obligations for foreign corporations that have been transporting cargo between U.S. ports under the historic waiver.

The IRS has finalized new Section 987 regulations that fundamentally change how businesses with foreign operations report currency gains and losses, with compliance beginning for the 2025 tax year. These regulations require taxpayers to calculate cumulative foreign currency positions dating back to 2006 or entity inception, while IRS Notice 2026-17 offers a simplified election that may reduce administrative burden for qualifying businesses. Understanding these changes now is critical to avoid penalties, ens

On Tuesday, August 11, 2026, the Treasury Department and the Internal Revenue Service (the IRS) issued a proposed rule (the “Proposed Rule”) laying out several requirements for employer contributions to Trump accounts, a tax-favored savings arrangement that may be established for eligible children under age 18 created by the One Big Beautiful Bill Act.