United States: Corporate Tax

Representative Mike Kelly has introduced legislation to establish up to 100 maritime prosperity zones across coastal areas, major rivers, and the Great Lakes, offering targeted tax incentives to maritime supply chain companies, workforce training programs, and advanced manufacturing operations. The proposal aligns with the Trump administration's broader initiative to revitalize the domestic maritime industry by layering new maritime designations onto the existing Qualified Opportunity Zones framework.

AI-generated performers like Tilly Norwood and Xania Monet are creating real revenue streams through licensing, streaming, and brand partnerships. How should creators, managers, and agencies structure ownership, navigate international tax obligations, and build sustainable business models around digital talent that exists entirely as intellectual property?

Several bipartisan legislative proposals affecting municipal bonds and infrastructure finance have been introduced in the 119th Congress, including measures to restore tax-exempt advance refunding, expand credit enhancement tools, and increase transparency requirements for nonprofit hospitals. While not currently at the forefront of the congressional agenda, these proposals represent long-standing priorities that could advance if tax or infrastructure legislation moves forward later this year.

The IRS and Treasury Department have announced plans to issue proposed regulations implementing significant changes to the definition of "covered employee" under Internal Revenue Code section 4960, which governs excise taxes on compensation exceeding $1 million paid to employees of applicable tax-exempt organizations. Notice 2026-36 provides interim guidance on how the One Big Beautiful Bill Act's expansion of covered employees will be interpreted, including which exceptions from prior regulations will be r

States are adopting divergent approaches to taxing prediction markets, ranging from aggressive enforcement and quasi-prohibitive tax regimes to cooperative models that recognize federal jurisdiction. This emerging patchwork creates significant questions about characterization, preemption, sourcing, and compliance that tax practitioners must navigate as the jurisdictional battle between state and federal regulators intensifies.

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.

This comprehensive bulletin examines critical tax developments across 12 Asian jurisdictions, including China's intensified scrutiny of Hong Kong holding company structures for dividend withholding tax benefits, Singapore's implementation of Pillar Two global minimum tax registration requirements, and India's new Income Tax Act taking effect.

The IRS has modified its list of taxable substances under the Superfund tax provisions to include two specialized rubber compounds following petitions from chemical importers and exporters. These additions will trigger tax obligations under Section 4671 of the Internal Revenue Code beginning October 1, 2026, while retroactive refund claims under Section 4662(e) will be available from April 1, 2023.

Most business owners believe they have succession planning under control. There is a trust. There is an entity structure. There may even be a buy-sell agreement in place. On paper, everything looks orderly.