United States: Tax

H. David Rosenbloom contributes an essay examining United States income tax treaties as part of a commemorative publication honoring Kees van Raad's nearly five decades of teaching international tax law. The essay explores the defense and significance of U.S. tax treaty policy within the broader context of international taxation.

Courts continue to shape the boundaries of state corporate income taxation, particularly in disputes involving P.L. 86-272 – which restricts states’ authority to impose income tax on certain interstate sellers – receipts sourcing, and the classification of business income.

The Pennsylvania Department of Revenue (DOR) recently revised Corporation Tax Bulletin 2019-03, limiting its application to tax years beginning before January 1, 2025. The change creates uncertainty for corporate taxpayers that previously relied on Pennsylvania’s federal consolidated-group approach to avoid a separate state-specific Section 163(j) limitation.

National Estate Planning Awareness Week serves as a timely reminder that estate planning isn't just for the wealthy or elderly—it's a crucial process for everyone. From designating guardians for minor children to managing beneficiary designations and planning for incapacity, comprehensive estate planning addresses far more than just asset distribution after death.

With the year ending, individuals and married couples have a valuable opportunity to reduce their taxable estates through strategic gifting. Understanding the $19,000 annual gift tax exclusion per recipient, along with unlimited direct payments for medical and educational expenses, can help you maximize tax-efficient wealth transfers before December 31.

The increased federal estate tax exemption under the One Big Beautiful Bill Act may have reduced the number of estates subject to federal estate tax, but for married New York residents, credit shelter trusts remain an important planning consideration.

Recent circuit court rulings from the Second and Fifth Circuits have reshaped the interpretation of the "limited partner" exception for self-employment tax purposes, moving away from purely legal-status definitions toward examining partners' actual roles in managing partnership businesses.

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The One Big Beautiful Bill Act transforms the qualified opportunity zone program by removing its 2026 expiration date and introducing enhanced incentives for long-term investments. Investors now face critical decisions about timing their 2026 gains, navigating new zone designations, and structuring funds to maximize tax benefits including a potential 30% basis increase for rural investments.

Partner Lauren Azebu examines the qualified small business stock (QSBS) gain exclusion rules under Section 1202, exploring the complexities that arise when QSBS is held through pass-through entities. The article analyzes technical issues including ownership limitations, transfer restrictions, and entity conversion strategies, while highlighting areas where guidance remains limited and emphasizing the importance of proactive planning.

The IRS and Treasury Department have issued proposed regulations addressing the allocation of deductions to foreign-source income under Section 951A, while recent Tax Court decisions clarify critical issues surrounding the Section 245A dividends-received deduction, consolidated return consents, and penalty assessment procedures. These developments carry significant implications for multinational corporations navigating foreign tax credit limitations and domestic loss calculations.

How are multinational enterprises adapting their transfer pricing (TP) strategies in response to the OECD’s Pillar One and Pillar Two implementations, particularly Amount B and the global minimum tax? What major changes do you anticipate in global TP guidance through 2026?