United States: Income Tax

Pre-acquisition tax planning isn’t just paperwork, it’s where you set the foundation for long-term success.

A Texas-based radiologist who performed all work from his home state faced California income tax assessments on earnings from a California company contract. The California Court of Appeal rejected the Franchise Tax Board's attempt to apply the unitary business principle to a sole proprietor, creating new grounds for non-resident individuals to challenge similar assessments.

The IRS has finalized its list of occupations eligible for the income tax deduction on qualified tips under the "One Big Beautiful Bill Act," making only minor modifications from its preliminary guidance. Employers must now prepare to report employee occupation codes and cash tip amounts on 2026 Form W-2s, while navigating new rules that distinguish between qualifying and non-qualifying tips based on job duties and payment circumstances.

Many founders make tax decisions that affect their exit from the business long before a buyer appears, when they’re still privately held and focused on growth rather than liquidity.

Qualified small business stock (QSBS) and non-QSBS issued to founders, employees and independent contractors is generally subject to Section 83.

The Tax Court's recent decision in Continental Grand Limited Partnership v. Commissioner addresses the complex interplay between retroactive entity classification elections and partnership basis calculations. When a German subsidiary retroactively elected to be disregarded as a separate entity before contributing a $610 million promissory note to a U.S. partnership, the court reordered the transaction with significant tax implications. The ruling extends established zero-basis principles to situations...

Bipartisan legislation aims to reduce compliance burdens on U.S. citizens living abroad by streamlining overlapping international financial reporting requirements and simplifying tax obligations.

The U.S. Department of the Treasury issued proposed regulations addressing two changes affecting the gaming industry and taxpayers: (i) an increase in the information reporting threshold for certain payees...

The IRS Whistleblower Program is one of the most powerful — and financially rewarding — tools in the U.S. enforcement system. Created to help expose serious tax fraud, evasion schemes, and large underpayments, the program allows individuals to report violations confidentially and earn up to 30% of the government’s recovery