United States: Corporate Tax

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Article
OZ 2.0 Proposed Regulations: What QOFs And Investors Need To Know
The IRS has issued proposed Treasury Regulations that would significantly expand reporting obligations and clarify certification rules for Qualified Opportunity Funds and Qualified Opportunity Zone Businesses. These proposed changes introduce new information return requirements, establish formal decertification procedures, and impose substantial penalties for non-compliance, fundamentally reshaping the administrative landscape for opportunity zone investments.
United States Tax
DW
Dickinson Wright PLLC
Article
Federal Agencies Issue Guidance On Employer Trump Account Contributions
The Treasury Department and IRS have issued new guidance on employer contributions to Trump Accounts, the tax-advantaged investment accounts for children created under President Trump's One Big Beautiful Bill. Employers can now make tax-free contributions of up to $2,500 annually to these Section 530A accounts for employees or their dependents, subject to specific plan requirements and non-discrimination rules.
United States Employment
HB
Hall Benefits Law
Article
Proposed Nondiscrimination Rule For Private School Admissions, Financial Assistance, And Other Programs
The IRS has proposed new regulations that would impose nondiscrimination requirements on private schools seeking to maintain their tax-exempt status under section 501(c)(3). These regulations would prohibit policies discriminating on the basis of race, color, or national or ethnic origin in admissions, financial assistance, and other school programs. The proposed rules raise important questions about how private schools can structure their programs while complying with federal tax law requirements.
United States Tax
JD
Jones Day
Article
Tax-Advantaged Employer Matching Contributions To Trump Accounts Now Available
The U.S. Department of Treasury has issued guidance on employer-sponsored Trump Account contribution programs, creating new tax-advantaged opportunities for employers to support employee savings for their children's future. Employers must navigate complex requirements analogous to dependent care assistance programs, including nondiscrimination rules, written plan documents, and compliance obligations under both the Internal Revenue Code and potentially ERISA. What are the key design considerations, tax impl
United States Employment
FH
Ford & Harrison LLP
Article
Coming Attractions: California Previews Rules On SaaS And Digital Products Tax
The California Department of Tax and Fee Administration (CDTFA) has released draft regulatory language it is considering proposing, offering its first comprehensive view of how it may administer Senate Bill 122, California's expansion of sales and use tax to software as a service (SaaS) and certain digital products beginning January 1, 2027. CDTFA has not yet formally proposed these regulations through the emergency rulemaking process.
United States Tax
HK
Holland & Knight
Article
Pennsylvania Decouples From Federal Interest Expense Rules
Pennsylvania's Department of Revenue has eliminated a key safe harbor for consolidated filers, requiring separate-company calculations of federal interest expense limitations under IRC Section 163(j) for Corporate Net Income Tax purposes starting in 2025. The new guidance introduces complex tracking requirements for intercompany interest, third-party debt, and carryforwards while freezing conformity to pre-OBBB rules, creating significant compliance challenges for multistate corporations.
United States Tax
HK
Holland & Knight
Article
Existing Opportunity Zone Investors Must Evaluate Planning Opportunities Before Dec. 31, 2026
The IRS has issued Notice 2026-40 providing transition guidance for investors who deferred capital gains under the original Opportunity Zone program. While December 31, 2026 remains the mandatory recognition date for deferred gains, the guidance reveals a potential planning opportunity that may allow certain investors to continue deferring gains under the new Opportunity Zone regime through strategic pre-year-end transactions.
United States Tax
JM
Jeffer Mangels & Mitchell LLP
Article
GT SALT Team On The Move (September–October 2026 Digest)
Greenberg Traurig's State and Local Tax team is hitting the road this fall with a packed schedule of speaking engagements at premier tax conferences across the country. From the COST Annual Meeting in San Antonio to the Hartman SALT Forum in Nashville, GT attorneys will address critical topics including legislative updates, apportionment issues, property tax developments, and multistate planning strategies that are shaping the state tax landscape.
United States Tax
GT
Greenberg Traurig, LLP
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