Tax Law and International Tax Law

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.
Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
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.
United States Tax
HL
Hogan Lovells Cadwalader
Article
Can You Change An Irrevocable Trust In New Jersey?
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.
United States Tax
SH
Scarinci Hollenbeck LLC
Article
The New Pied-à-Terre Tax In New York City: What Domestic And Foreign Owners Need To Know
New York City has implemented a significant annual surcharge on high-value residential properties that don't serve as primary residences, affecting second-home owners, foreign investors, and luxury property holders. The tax, which took effect July 1, 2026, applies graduated rates based on property valuations and is expected to generate approximately $500 million annually. Property owners face tight deadlines to claim exemptions and must navigate complex documentation requirements to prove primary residence
United States Tax
LB
Lewis Brisbois Bisgaard & Smith LLP
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Tax Disputes

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Tax Treaties

Article
Proposed Regulations Implement OBBBA Changes To Income Inclusions Resulting From Sales Of Controlled Foreign Corporation Stock
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.
United States Tax
HL
Hogan Lovells Cadwalader
Article
IRS Issues Proposed Regulations Excluding Income From Certain Property Sales From FDDEI Under Section 250(b)(3)(A)(i)(VII)
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.
United States Tax
AO
A&O Shearman
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Transfer Pricing

Article
IRS Issues Proposed Regulations Excluding Income From Certain Property Sales From FDDEI Under Section 250(b)(3)(A)(i)(VII)
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.
United States Tax
AO
A&O Shearman
Article
Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge
The US Department of Treasury defends its authority to regulate stock-based compensation in cost-sharing arrangements under IRC § 482, arguing the regulations fall within statutory bounds and are necessary to ensure arm's-length results between related parties. The government's response to McKesson Corporation's summary judgment motion addresses challenges based on the Loper Bright decision and notably abandons its six-year statute of limitations defense.
United States Tax
SR
McDermott Will & Schulte
Article
Daniel Keller Hosted The American Bar Association’s People In Tax Podcast Episode, “Bonus Episode: Professor Jeremy Bearer-Friend."
Discover how artificial intelligence is transforming tax law and intellectual property, while examining critical issues of tax rates and wealth inequality in modern America. Professor Jeremy Bearer-Friend from George Washington University Law School shares expert insights on these evolving challenges in the tax landscape.
United States Tax
DW
Dickinson Wright PLLC
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Property Taxes

Article
The New Pied-à-Terre Tax In New York City: What Domestic And Foreign Owners Need To Know
New York City has implemented a significant annual surcharge on high-value residential properties that don't serve as primary residences, affecting second-home owners, foreign investors, and luxury property holders. The tax, which took effect July 1, 2026, applies graduated rates based on property valuations and is expected to generate approximately $500 million annually. Property owners face tight deadlines to claim exemptions and must navigate complex documentation requirements to prove primary residence
United States Tax
LB
Lewis Brisbois Bisgaard & Smith LLP
Article
Florida’s Revised Property Tax Amendment Ballot Language
This amendment increases the homestead exemption, for all non-school taxes, to $150,000 in 2027, and $250,000 in 2028, and adjusts for inflation thereafter. It requires the legislature to prescribe a uniform procedure for counties and municipalities, for their respective levies, to increase the homestead exemption up to full assessed value, and allows special districts, subject to referendum approval, to do the same.
United States Tax
JW
Jones Walker
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Income Tax

Article
Can You Change An Irrevocable Trust In New Jersey?
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.
United States Tax
SH
Scarinci Hollenbeck LLC
Article
Education Freedom Tax Credit To Take Effect In 2027: Proposed Regulations Expected Soon
The One Big Beautiful Bill Act introduces Section 25F of the Internal Revenue Code, establishing a federal tax credit of up to $1,700 annually for individual taxpayers who contribute to eligible Scholarship Granting Organizations beginning in 2027. States must voluntarily elect to participate and identify qualifying SGOs, which face federal requirements for scholarship distributions, student eligibility verification, accounting practices, audits and reporting obligations. As the U.S. Department of the Treas
United States Tax
HK
Holland & Knight
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