Tax Law and International Tax Law

Portability of estate and gift tax enables a surviving spouse to inherit any unused portion of their deceased spouse's federal estate and gift tax exemption, potentially doubling the exemption amount. While this powerful mechanism can help married couples preserve unused tax exemptions and minimize transfer tax liability, it is frequently misunderstood, underutilized, or improperly elected. Understanding the statutory framework, mechanics...

Recent tax developments include New York City's new property tax surcharge on high-value pied-à-terre homes and potential changes to IRS Form 1040 that would require disclosure of citizenship status and dual citizenship. These policy shifts reflect growing efforts to address tax equity in luxury real estate markets and enhance transparency in tax reporting for individuals with complex international ties.

Louisiana voters will have the opportunity to expand property tax relief for senior homeowners when a proposed constitutional amendment appears on the statewide ballot on November 3, 2026.

Companies often grant equity incentives to their executives and key employees in the form of restricted equity.

Washington State has enacted a new 9.9% income tax on individual earnings exceeding $1 million annually, effective January 2028.

Employer-issued recourse promissory notes allow employees to acquire equity without immediate cash outlay, but they create personal liability regardless of stock performance. This analysis examines the strategic advantages, tax implications, and significant risks that both companies and employees face when using this compensation structure.

Global families investing in U.S. real estate face critical tax structuring decisions at acquisition that can either preserve wealth or create decades of avoidable exposure. How should international investors structure their U.S. property purchases to minimize estate tax, FIRPTA obligations, and state tax compliance issues before closing the deal?

Understanding foreign tax credits is essential for taxpayers with international income. This analysis examines the qualification criteria for creditable foreign taxes, the basket system that limits cross-crediting across income categories, and the procedural requirements for claiming these credits on U.S. tax returns.

As family offices across the Middle East continue to grow in both sophistication and ambition, many are increasingly looking to the United States as a destination for capital deployment.

The U.S. Department of Treasury and Internal Revenue Service held a three-day hearing in May 2026 to address industry concerns about proposed regulations for the Section 45Z clean fuel production tax credit.

The Schedule K-1 is a tax form that pass-through entities use to report each owner’s share of the entity’s income, deductions, credits, and other tax items. It is also one of the great rock stars of business divorce...

Employers designing executive compensation often overlook Internal Revenue Code Section 409A, which governs non-qualified deferred compensation with strict rules on timing of deferrals and distributions. When these technical requirements aren't met...