Worldwide: Tax Authorities

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

The North Carolina Department of Revenue has issued guidance on three significant tax changes affecting individual and corporate income tax returns. These changes include new rules for domestic research and experimental expenditures, a special deduction for timber casualty losses from Hurricane Helene, and expanded gambling loss deductions. Understanding how these legislative updates impact your tax filing obligations and whether amended returns are necessary is crucial for compliance.

On June 16, 2026, Governor Pritzker signed Public Act 104-0468 into law. The Illinois Act makes two significant income tax changes: it decouples Illinois from the federal qualified small business stock (“QSBS”) gain exclusion under Code Section 1202 and further restricts the use of corporate net operating loss (“NOL”) carryover deductions.

California's Department of Tax and Fee Administration held its first implementation workshop on Senate Bill 122, which extends sales and use tax to digital software and SaaS starting January 1, 2027. The workshop revealed significant unresolved questions about sourcing rules, the $5 million threshold mechanism, custom versus prewritten software distinctions, and the human-effort exemption that will require emergency regulations and potentially litigation to clarify.

The IRS Office of Professional Responsibility has issued new guidelines clarifying how existing Circular 230 obligations apply when tax practitioners use generative AI in their practice. These guidelines establish that while AI can assist professional judgment in tax work, it cannot replace the practitioner's ultimate responsibility for accuracy, competence, confidentiality, and ethical billing practices.

The forms support the final Section 987 regulations issued in December 2024, which provide guidance for determining taxable income, loss, and earnings and profits for qualified business units (QBUs) that use a different functional currency than their owners. The regulations apply to tax years beginning in 2025.

The IRS and Treasury Department have issued new guidance addressing how contributions to Trump Accounts are treated for federal gift tax purposes, creating a safe harbor for qualifying donors. Revenue Procedure 2026-25 establishes specific requirements that allow certain contributions to be treated as completed gifts of a present interest, eligible for the annual gift tax exclusion without requiring Form 709 filing. Understanding these requirements is critical for donors to ensure compliance and avoid unnec

S corporation shareholders who elected to defer the Section 965 transition tax under the Tax Cuts and Jobs Act face ongoing compliance obligations and potential acceleration risks. Understanding the strict filing deadlines, triggering events, and annual reporting requirements is essential to avoid unexpected tax liabilities and costly penalties that can arise from routine business transactions or estate planning activities.

The IRS and Treasury Department have announced plans to issue proposed regulations implementing significant changes to the definition of "covered employee" under Internal Revenue Code section 4960, which governs excise taxes on compensation exceeding $1 million paid to employees of applicable tax-exempt organizations. Notice 2026-36 provides interim guidance on how the One Big Beautiful Bill Act's expansion of covered employees will be interpreted, including which exceptions from prior regulations will be r