United States: Tax Authorities

U.S. companies making cross-border dispute payments face unexpected tax liability when withholding requirements are overlooked. Understanding how the origin of the claim doctrine characterizes settlements and damages as FDAP income can prevent costly surprises and ensure proper tax compliance in international dispute resolution.

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes as European profits were generated, (ii) the integration of European tax plans with U.S. tax concepts to prevent Subpart F from applying to intercompany transactions in Europe, and (iii) the reduction of withholding taxes and U.S. tax under Subpart F as profits were distributed through a chain of European companies and

Now that we are halfway through 2026, we want to provide a summary of the proposed and enacted wealth taxes emerging in states and localities. Our mid-year update surveys six recent developments...

In Supreme Linen Services, Inc. v. U.S., 2026 WL 1220078 (S.D. Fla. 2026), an employer sued the federal government after the Internal Revenue Service (IRS) assessed an employer shared responsibility penalty...

The Mississippi Department of Revenue has amended several sales and use tax regulations following a state Supreme Court ruling that challenged the Department's authority to impose use tax on third-party freight charges. These regulatory changes eliminate provisions that had been in place for years, fundamentally altering how businesses must handle use tax accruals on shipping and delivery expenses paid to parties other than the seller of goods.

The IRS has introduced a new administrative pathway for taxpayers facing imminent deadlines on denied Employee Retention Credit claims, allowing them to request extensions without immediately filing costly lawsuits. This development addresses the overwhelming backlog at the Independent Office of Appeals and provides relief for taxpayers caught between abandoning legitimate claims or incurring litigation expenses. Understanding eligibility requirements and submission procedures through Form 907 is essential

High-net-worth families are restructuring their family offices using the Lender model to qualify as separate trades or businesses for federal tax purposes. This strategic shift enables them to deduct investment-related expenses that were eliminated for individuals under the Tax Cuts and Jobs Act, creating significant tax efficiency opportunities through carefully designed management entities and allocation structures.

In a detailed discussion of California tax apportionment law, tax practitioners examine the landmark Smithfield Foods case and its implications for agricultural business classification and alternative apportionment methods.

The Internal Revenue Service has launched a nationwide recruitment initiative to fill critical seasonal positions across the country through the end of July 2026.