United States: Tax

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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
IRS Releases 2026 Energy Community Bonus Credit Updates For Statistical Areas And Coal Closures
The IRS has issued Notice 2026-39, providing crucial updates to the energy community bonus credit guidance under the Inflation Reduction Act. This latest guidance expands the list of qualifying counties and census tracts for the statistical area and coal closure categories, potentially opening new opportunities for renewable energy projects to claim enhanced tax credits. The notice includes three detailed appendices with updated geographic eligibility data based on 2025 unemployment statistics and newly ide
United States Tax
HK
Holland & Knight
Article
Ten Minute Interview: Reducing Transaction Risk (Video)
First enacted in 1993, Qualified Small Business Stock (QSBS) has emerged as one of the most powerful wealth-building mechanisms available to founders, early employees, and venture investors. Section 1202 of the Internal Revenue Code provides substantial tax benefits, allowing up to $15 million in capital gains to be shielded from federal taxes on qualifying stock sales. With Congress expanding the exclusion in 2025, understanding the requirements and strategic implications of QSBS has become increasingly cr
United States Tax
FL
Foley & Lardner
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Tax Disputes

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Tax Treaties

Article
Certainty By Design: A Practical Guide To Prefiling Agreements, Closing Agreements, Private Letter Rulings, And Tax Opinions
Tax executives face material transactions that cannot wait for litigation to resolve interpretive uncertainty. This practical guide explores four critical IRS mechanisms—prefiling agreements, closing agreements, private letter rulings, and tax opinions—that provide varying levels of certainty for managing tax exposure before issues reach examination. Through conversations between controversy and transactional practitioners, discover when and how to deploy these tools along the continuum from inf
United States Tax
DS
Dinsmore & Shohl
Article
Letter From The Editors: The Next Chapter Of BrassTax
As Cadwalader approaches its merger with Hogan Lovells on July 1, the firm reflects on eight years of BrassTax publication, which has provided clear insights on major tax developments from the 2017 Tax Cuts and Jobs Act to cryptocurrency taxation and energy tax credits. The publication will integrate into the combined firm's platform over the summer, promising expanded coverage with a broader group of contributors in the fall.
United States Tax
HL
Hogan Lovells Cadwalader
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Inheritance Tax

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Supreme Court Rejects Trump’s Birthright Citizenship Challenge: Why Renouncing US Citizenship Remains The Optimal Tax Solution For US Expats
The US Supreme Court's June 2026 decision upholding birthright citizenship has significant implications for American expatriates who hoped a policy change might release them from lifelong US tax obligations. For "accidental Americans" born in the US but living abroad with minimal connection to the country, the ruling confirms that citizenship—and its accompanying worldwide tax filing requirements, foreign account reporting, and estate tax exposure—remains an inescapable reality unless formally r
United States Tax
MP
Moodys Private Client Law LLP
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Income Tax

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Transfer Pricing

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The Impact of AI Tools on Transfer Pricing and Value Creation
As artificial intelligence transforms business operations, multinational enterprises face critical questions about where value is created when significant human functions are automated. This analysis examines how the arm's length principle should be applied to controlled transactions involving AI tool development and deployment, with particular focus on risk control functions and the attribution of AI investments across evolving value chains.
United States Tax
N
NERA
Article
Illinois Proposed Addback Regulations Raise Questions On Clarity, Administrability
Greenberg Traurig shareholder Breen Schiller has submitted formal comments and testimony to Illinois tax authorities regarding proposed amendments to regulations governing addbacks for interest and intangible expenses in transactions with 80/20 companies. The comments address concerns about conduit exception narrowing, limitations on the "unreasonable" standard, and reliance on private letter rulings that may create administrability challenges for Illinois businesses.
United States Tax
GT
Greenberg Traurig, LLP
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