United States: Corporate Tax

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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
IRS Proposes New Racial Nondiscrimination Regulations For Tax-exempt Private Schools
The US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.
United States Tax
SR
McDermott Will & Schulte
Article
New York’s Revised P.L. 86-272 Regulation Survives Judicial Appeal
A New York appellate court recently ruled on the state's revised P.L. 86-272 regulation, determining it is not facially preempted by federal law but cannot be applied retroactively before December 2023. The decision leaves open the possibility of future taxpayer-specific challenges while providing clarity on how internet-based business activities may affect state tax obligations for out-of-state sellers.
United States Tax
MG
MGO CPA LLP
Article
6 Critical Actions To Take Before An R&D Credit Audit
The IRS is intensifying scrutiny of federal R&D tax credit claims under Section 41, with recent Form 6765 changes giving examiners unprecedented visibility into credit details. Court decisions have reinforced that audit outcomes hinge on the quality and alignment of company records with IRS requirements, making documentation and preparation critical for companies with substantial credits at stake.
United States Tax
SR
McDermott Will & Schulte
Article
IRS Issues Guidance On Section 45Z Clean Fuels Production Tax Credit To Support Domestic Biofuel Production And American Agriculture
The IRS has released new guidance on the Section 45Z Clean Fuels Production Tax Credit, introducing significant changes that affect how American farmers, ranchers, and fuel producers can access benefits from the domestic biofuels market. Notice 2026-53 provides updated emissions rate tables and addresses critical modifications mandated by the Working Families Tax Cuts, including special provisions for manure-derived fuels and regenerative agricultural practices.
United States Tax
BC
Bergeson & Campbell
Article
LP-Led CFOs: Their Rise And Key Considerations
Collateralized fund obligations (CFOs) have emerged as a sophisticated securitization tool for institutional investors seeking to monetize their private fund portfolios while retaining upside exposure. This analysis examines the unique structural, tax, and regulatory challenges that distinguish LP-led CFO transactions from their GP-led counterparts, revealing why these deals require more extensive preparation and specialized expertise to execute successfully.
United States Finance
D
Dechert
Article
US LLCs And Foreign Owners: What International Entrepreneurs Need To Know
Foreign ownership of US limited liability companies creates complex tax reporting obligations that many entrepreneurs overlook. Even LLCs with no US-source income may face annual filing requirements and penalties starting at $25,000 for non-compliance. Understanding these obligations before formation can help avoid costly administrative burdens and unexpected tax consequences.
United States Tax
GGI Global Alliance
Article
Treasury And IRS Issue Guidance On Emissions Rates For Clean Fuel Production Credit
The US Department of the Treasury and IRS have released new guidance establishing emissions rate tables and feedstock practices for the Section 45Z clean fuel production credit. The Notice addresses emissions rates for animal manure-derived transportation fuels and outlines how regenerative agricultural practices factor into credit calculations. Concurrently, the Department of Energy updated the 45ZCF-GREET model to include additional renewable natural gas pathways.
United States Environment
B
Bracewell
Article
US Expats Face Another Tax Setback In The Courts: Is It Time To Finally Renounce US Citizenship?
Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.
United States Tax
MP
Moodys Private Client Law LLP
Article
IRC Section 280E And Cannabis Tax Planning: Recent Developments And Practical Considerations
The landscape surrounding Section 280E of the Internal Revenue Code continues to evolve with President Trump's Executive Order on medical marijuana rescheduling, advancing litigation in New Mexico Top Organics v. Commissioner, and shifting regulatory signals. Cannabis taxpayers face critical decisions about taking "non-280E" positions on their tax returns while the IRS maintains its enforcement stance and the U.S. Tax Court case addressing common arguments remains pending.
United States Cannabis
FH
Foley Hoag LLP
Podcast
Coffee Chats With WIN: Don’t Take Yourself Out Of The Game (Podcast)
In this episode of Coffee Chats with WIN, hosts Jessica Stewart and Lauren Russell sit down with Lesley Adamo, Vice Chair of the Tax Group and New York Office Managing Partner at Lowenstein Sandler. Lesley shares her journey into tax law, the pivotal advice that shaped her path to partnership while balancing family life, and why bringing your authentic self to work matters.
United States Employment
LS
Lowenstein Sandler
Article
Section 45Z 2026 Emissions Rate Table And Updated GREET Model Published
The U.S. Department of the Treasury and IRS have released Notice 2026-53, establishing new emissions rate tables for the Section 45Z clean fuel production tax credit and implementing key amendments from the One Big Beautiful Bill Act. The notice introduces distinct emissions rates for transportation fuels derived from animal manure, permits farm-specific alternative fate determinations, and addresses the exclusion of indirect land use change emissions.
United States Tax
HK
Holland & Knight
Article
IRS Proposes Sweeping Nondiscrimination Rules Impacting Tax-Exempt Private Schools
The U.S. Treasury Department and IRS have proposed sweeping regulations that would eliminate tax-exempt status for private schools engaging in any form of racial discrimination, including race-conscious admissions and scholarship programs previously permitted under safe harbor provisions. These proposed rules would affect approximately 18,000 private educational institutions and 750,000 students...
United States Tax
HK
Holland & Knight
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
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