Tax Law and International Tax Law

When it comes to estate planning, even the rich and famous are not immune to costly mistakes. This examination of celebrity estate planning mishaps reveals how iconic figures have fallen victim to oversights leading to legal battles, unintended heirs, and millions in tax losses, offering valuable lessons for legal professionals and individuals alike.

The U.S. tax landscape has undergone dramatic transformation since the Tax Cuts and Jobs Act of 2018, with evolving rules, expiring provisions, and major legislation during President Trump's second term. This analysis examines the six most significant tax developments of the past eight years, from historic estate tax exemption increases to the growing importance of international taxation, and explores what these changes mean for taxpayers, advisors, and business owners navigating today's more stable but sti

A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.

Idaho's newly approved Opportunity Zones offer tax incentives to investors who fund development projects in designated communities across the state. The program connects private capital with real estate and business ventures in areas including Boise, Coeur d'Alene, and Post Falls, potentially bringing new housing, jobs, and economic activity to these regions.

An S corporation election offers early-stage tax advantages but introduces significant constraints on venture financing, equity compensation structures, and exit strategies. Understanding five key restrictions—from shareholder eligibility rules to QSBS disqualification—helps founders determine whether S corporation status aligns with their growth trajectory and capital-raising plans.

The federal Opportunity Zone program has been made permanent through the One Big Beautiful Bill Act, introducing significant changes to tax deferral rules, census tract designations, and investment incentives. Understanding how Opportunity Zones 2.0 differs from the original program is critical for business owners, investors, and real estate developers planning transactions in 2026 and beyond.

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.

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.

A New York Court of Claims judge has ordered substantial revisions to how New York City administers its Pied-à-Terre tax surcharge, canceling previously issued notices and shifting the burden of proof to the Department of Finance. The ruling requires individualized determinations before notices can be sent and eliminates the controversial exemption application process that had confused thousands of property owners. While the decision doesn't strike down the PAT law itself, it fundamentally restructures

The US Treasury and IRS have issued new guidance targeting ETF tax strategies, including the controversial '351 conversion transaction' that allows investors to defer taxation on appreciated securities. Revenue Ruling 2026-20 and Notice 2026-62 identify multiple strategies as potentially abusive, signaling increased scrutiny of tax deferral mechanisms used by exchange-traded funds and investment partnerships.