Worldwide: Tax

The Treasury Department has issued proposed regulations fundamentally changing how U.S. shareholders calculate their pro rata share of controlled foreign corporation income when ownership interests vary throughout the year. These regulations implement amendments from the One Big Beautiful Bill Act, introducing daily proration methodologies, mandatory year-end closings for status changes, and new elective provisions for significant ownership variances.

The Maryland Tax Court struck down the state's digital advertising tax on multiple constitutional grounds, potentially establishing a precedent for challenging similar state taxes targeting the digital economy. The decisions address fundamental questions about how states can tax digital services without violating federal law and constitutional protections.

The U.S. Treasury and IRS have issued proposed regulations addressing a new category of income excluded from deduction eligible income under section 250(b)(3)(A)(i)(VII), which was introduced by the One Big Beautiful Bill Act. These regulations clarify how income from sales of intangible property and certain depreciable assets will be treated under the foreign-derived deduction eligible income regime, with significant implications for software transactions and related party transfers.

When adding a partner or outside investor to your business, understanding the tax implications is crucial for both personal and business finances. This comprehensive guide explores entity structure considerations...

The One Big Beautiful Bill Act has fundamentally transformed Section 1202's qualified small business stock (QSBS) tax benefits, introducing tiered holding periods that allow partial capital gains exclusions...

Illinois has enacted legislation that decouples the state’s income tax from the federal exclusion for gain from the sale of Qualified Small Business Stock (QSBS).

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.

In New Jersey, irrevocable trusts can sometimes be modified through a process called decanting, which allows trustees to transfer assets into a new trust with different terms. Understanding when decanting is available under common law, what discretion trustees must have, and what tax and fiduciary risks are involved is essential for anyone administering or benefiting from an irrevocable trust in the state.

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 August 2026 Section 7520 rate remains at 5.20% for estate planning techniques. Treasury Decision 10051 targets CRAT abuse schemes as listed transactions requiring disclosure. New guidance addresses Trump Account contributions, charitable LLC arrangements face IRS scrutiny, and Florida introduces streamlined trustee discharge procedures.