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
Education Freedom Tax Credit To Take Effect In 2027: Proposed Regulations Expected Soon
The One Big Beautiful Bill Act introduces Section 25F of the Internal Revenue Code, establishing a federal tax credit of up to $1,700 annually for individual taxpayers who contribute to eligible Scholarship Granting Organizations beginning in 2027. States must voluntarily elect to participate and identify qualifying SGOs, which face federal requirements for scholarship distributions, student eligibility verification, accounting practices, audits and reporting obligations. As the U.S. Department of the Treas
United States Tax
HK
Holland & Knight
Article
Treasury And IRS Expand And Extend Section 45Q Reporting Safe Harbors
On August 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (the IRS), in consultation with the Administrator of the Environmental Protection Agency (the EPA), the Secretary of Energy, and the Secretary of the Interior, released Notice 2026-50 (the Updated Notice), which modifies and amplifies guidance under Section 45Q of the Internal Revenue Code of 1986, as amended (the Code), that was introduced in December under Notice 2026-1.
United States Tax
B
Bracewell
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Tax Treaties

Article
New IRS Section 987 Rules: What Every Business Owner With Foreign Operations Needs To Know
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
United States Tax
MG
MGO CPA LLP
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Inheritance Tax

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Income Tax

Article
Education Freedom Tax Credit To Take Effect In 2027: Proposed Regulations Expected Soon
The One Big Beautiful Bill Act introduces Section 25F of the Internal Revenue Code, establishing a federal tax credit of up to $1,700 annually for individual taxpayers who contribute to eligible Scholarship Granting Organizations beginning in 2027. States must voluntarily elect to participate and identify qualifying SGOs, which face federal requirements for scholarship distributions, student eligibility verification, accounting practices, audits and reporting obligations. As the U.S. Department of the Treas
United States Tax
HK
Holland & Knight
Article
The Refs Review The Play: Fifth Circuit Tightens The Rules For Self-Employment Taxes On Partnership And LLC Owners
The Fifth Circuit Court of Appeals has modified its stance on self-employment taxes for pass-through entity owners, moving from a simple liability-based test to a more nuanced "significance" test that examines an owner's involvement in business operations. This shift creates uncertainty for LLC and partnership owners who must now evaluate whether their management role is "significant" enough to trigger self-employment tax obligations, while traditional limited partners may still find safe harbor from these
United States Tax
N
Nossaman LLP
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Transfer Pricing

Article
Government Drops Statute Of Limitations Defense In McKesson Cost-sharing Challenge
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.
United States Tax
SR
McDermott Will & Schulte
Article
Daniel Keller Hosted The American Bar Association’s People In Tax Podcast Episode, “Bonus Episode: Professor Jeremy Bearer-Friend."
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.
United States Tax
DW
Dickinson Wright PLLC
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