United States: Income 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
How An S Corporation Election May Affect Financing And Exit
An S corporation election offers early-stage tax advantages but introduces significant constraints on venture financing, equity compensation structures, and exit strategies. Understanding five key restrictions—from shareholder eligibility rules to QSBS disqualification—helps founders determine whether S corporation status aligns with their growth trajectory and capital-raising plans.
United States Tax
GU
Gesmer Updegrove LLP
Article
Emergency Tax Relief On Diesel Fuel (Trump EO Tracker)
In response to constrained global diesel supplies and rising fuel costs, the Treasury Department is directed to provide temporary tax relief for farmers, truckers, and other affected taxpayers. The order mandates deferral of diesel excise taxes incurred between October and December 2026, while also directing agencies to explore options for permanently forgiving these deferred obligations. Implementation requires coordination across Treasury, IRS, Agriculture, and Transportation departments to balance relief
United States Tax
AG
Akin Gump Strauss Hauer & Feld LLP
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
Second Circuit Furthers Circuit Split By Affirming Functional Test For “Limited Partner” Self-Employment Tax Exception
The Second Circuit has affirmed the Tax Court’s rulings against Soroban Capital Partners LP, holding that the firm’s three principals were not “limited partners” for purposes of the self-employment tax exclusion found in I.R.C. § 1402(a)(13), despite formally holding limited partner status under Delaware law. Under the Internal Revenue Code, a partner’s distributive share of partnership income is generally treated as self-employment income subject to the 15.3 percent self-employment tax on income up to $184,500 in 2026 (2.9 percent rate above that threshold), which funds Social Security and Medicare. Section 1402(a)(13), however, excludes from that tax the distributive share of a “limited partner, as such,” other than guaranteed payments for services rendered.
United States Tax
LL
Liskow & Lewis
Article
US Expats Face Another Tax Setback In The Courts: Is It Time To Finally Renounce US Citizenship?
Recent US court rulings have confirmed that foreign tax credits cannot offset the Net Investment Income Tax for American citizens living abroad, creating an additional layer of taxation even when income is already taxed in their country of residence. These decisions raise critical questions about the long-term viability of maintaining US citizenship for entrepreneurs and business owners who have permanently established their lives outside the United States.
United States Tax
MP
Moodys Private Client Law LLP
Article
IRS Finalizes Rules On The New Car Loan Interest Deduction
The Treasury Department and IRS issued final regulations implementing the new deduction for qualified passenger vehicle loan interest (QPVLI), a temporary benefit created by the One, Big, Beautiful Bill Act (OBBBA) that allows individuals to deduct up to $10,000 of interest paid on certain auto loans, even if they do not itemize deductions. The final rules largely adopt the proposed regulations issued in January 2026 but include clarifications in response to public comments received by the Treasury Department.
United States Tax
LL
Liskow & Lewis
Article
Latest Tax Updates: Trump Account Investment Rules, Subpart F Proration, And Conservation Easement Enforcement
The IRS and Treasury Department issued significant guidance in late August 2026 on Trump Accounts, CFC income calculations, and conservation easement enforcement, while federal appellate courts delivered pivotal rulings on the limited partner exception to self-employment tax and the Anti-Injunction Act's scope. These developments reshape tax compliance strategies for individuals, corporations, and partnerships navigating charitable deductions, international income allocation, and procedural challenges.
United States Tax
SR
McDermott Will & Schulte
Article
Georgia Enacts Key SALT Legislation: What Taxpayers Should Know
Georgia's 2026 legislative session brought significant state tax changes, including updated IRC conformity rules that deliberately diverge from federal law in key areas. While the state adopted many provisions from the federal One Big Beautiful Bill Act, it declined to follow federal treatment of tips, overtime pay, SALT deductions, and bonus depreciation—creating important compliance considerations for businesses operating in the state.
United States Tax
MG
MGO CPA LLP
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