United States: Tax

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

The IRS recently released Revenue Procedure 2026-25, which establishes a transfer tax safe harbor for certain contributions to Trump Accounts.

U.S. companies making cross-border dispute payments face unexpected tax liability when withholding requirements are overlooked. Understanding how the origin of the claim doctrine characterizes settlements and damages as FDAP income can prevent costly surprises and ensure proper tax compliance in international dispute resolution.

Although IRS enforcement efforts have evolved, estate and gift tax examinations remain an area of focus, particularly for high value estates and sophisticated wealth transfer transactions.

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.

When adding a partner or outside investor to your business, understanding the tax implications is crucial for both personal and business finances. This comprehensive guide explores entity structure considerations...

Navigating the complex landscape of US federal income tax rules is crucial for investors and sponsors in private equity, venture capital, and hedge funds. Understanding how different investor categories—from US taxable entities to foreign pension funds—face distinct tax sensitivities can significantly impact investment returns and structural decisions when forming or investing in funds.

Illinois has enacted legislation that decouples the state’s income tax from the federal exclusion for gain from the sale of Qualified Small Business Stock (QSBS).

On the morning of 21 July 2026 at a meeting of the Wall Street Tax Association, officials from the Internal Revenue Service (IRS) and Department of Treasury (Treasury) joined in a discussion with income tax...

The United States Court of Federal Claims has issued a landmark decision in Alta Wind I Owner Lessor C v. United States, rejecting the use of discounted cash flow methodology for calculating eligible basis in renewable energy tax credits and instead adopting a cost approach based on reproduction costs. This ruling, which concludes a 13-year legal battle over Section 1603 cash grants, establishes that anticipated tax credit values cannot be included in the basis calculation and has immediate implications for

As the global tax controversy landscape evolves and becomes more polarized, marked by cross-border audits and mounting pressure on revenue authorities to collect tax, Jones Day partners examine how geopolitical pressure and rising revenue demands are reshaping tax disputes worldwide. The discussion highlights the complexity of navigating uncertain tax environments where authorities are increasingly sharing information across borders and deploying sophisticated anti-abuse provisions.