United States: Tax

The IRS has introduced a new Automatic Exemption from Penalty program while a federal court struck down key GILTI regulations in a significant post-Loper Bright decision. The Treasury and IRS also finalized guidance on life insurance contract transactions and updated various energy-related tax credits and reporting requirements.

The IRS has finalized new Section 987 regulations that fundamentally change how businesses with foreign operations report currency gains and losses, with compliance beginning for the 2025 tax year. These regulations require taxpayers to calculate cumulative foreign currency positions dating back to 2006 or entity inception, while IRS Notice 2026-17 offers a simplified election that may reduce administrative burden for qualifying businesses. Understanding these changes now is critical to avoid penalties, ens

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...

The August 2026 Section 7520 rate remains at 5.20% for estate planning techniques. Treasury Decision 10051 targets CRAT abuse schemes as listed transactions requiring disclosure. New guidance addresses Trump Account contributions, charitable LLC arrangements face IRS scrutiny, and Florida introduces streamlined trustee discharge procedures.

The IRS has released updated pension interest rates and August applicable federal rates while intensifying examinations of noncash charitable contributions. Recent Tax Court decisions have invalidated...

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 Treasury Department and IRS have issued Notice 2026-50, expanding the safe harbor for section 45Q carbon capture tax credits by extending Subpart RR reporting requirements to enhanced oil recovery projects and establishing a transition period tied to future guidance. This interim relief addresses critical gaps in the carbon capture regulatory framework while Treasury seeks public comment on permanent alternatives to EPA's Greenhouse Gas Reporting Program requirements.

This roundup examines critical IRS developments spanning executive nominations, procedural relief mechanisms, and landmark court decisions that reshape tax collection enforcement and whistleblower award determinations. From supervisory approval requirements for penalty assessments to jurisdictional questions in Collection Due Process proceedings, these developments carry significant implications for taxpayers navigating federal tax controversies and compliance obligations.

For the better part of a decade, every estate planning conversation my colleagues had with a high-net-worth family started with the same clock: the 2017 Tax Cuts and Jobs Act exemption was set to sunset at the end of 2025, and attorneys, advisors and trustees were racing to get gift programs, spousal lifetime access trusts (SLATs) and irrevocable trusts funded before it reverted to pre-2017 levels.

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.

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.

When US multinationals establish operations in Europe, determining how much profit should be allocated to a permanent establishment becomes critical. The Authorised OECD Approach requires a functional...