United States: Tax Authorities

On July 1, 2026, the IRS quietly eliminated the Delinquent FBAR Submission Procedures, the long-standing administrative program that encouraged voluntary compliance...

Although IRS enforcement efforts have evolved, estate and gift tax examinations remain an area of focus, particularly for high value estates and sophisticated wealth transfer transactions.

On the morning of 21 July 2026 at a meeting of the Wall Street Tax Association, officials from the Internal Revenue Service (IRS) and Department of Treasury (Treasury) joined in a discussion with income tax...

Prior to 2018, widely-used tax plans of U.S.-based multinational groups were designed to achieve three basic goals in connection with European operations: (i) the reduction of European taxes as European profits were generated, (ii) the integration of European tax plans with U.S. tax concepts to prevent Subpart F from applying to intercompany transactions in Europe, and (iii) the reduction of withholding taxes and U.S. tax under Subpart F as profits were distributed through a chain of European companies and

Now that we are halfway through 2026, we want to provide a summary of the proposed and enacted wealth taxes emerging in states and localities. Our mid-year update surveys six recent developments...

The U.S. Department of the Treasury announced a major transparency initiative on April 23, 2026, that could lead to expanded reporting requirements for tax-exempt organizations.

The IRS has begun issuing Notice CP53E to taxpayers whose direct deposit information is missing or invalid, but some notices may have been sent in error. Fraudsters are exploiting this confusion by distributing convincing fake versions of the notice designed to steal personal and financial information. Tax professionals and taxpayers must carefully verify all IRS communications before providing sensitive banking details.

Tax executives face material transactions that cannot wait for litigation to resolve interpretive uncertainty. This practical guide explores four critical IRS mechanisms—prefiling agreements, closing agreements, private letter rulings, and tax opinions—that provide varying levels of certainty for managing tax exposure before issues reach examination. Through conversations between controversy and transactional practitioners, discover when and how to deploy these tools along the continuum from inf

Illinois has enacted the nation's first digital asset transaction tax, effective January 2027, imposing a 0.2% levy on cryptocurrency exchanges, transfers, and storage. Brokers must register before conducting any Illinois transactions, with the state presuming all receipts are taxable unless proven otherwise. The groundbreaking legislation faces potential constitutional challenges while creating new compliance obligations for digital asset platforms nationwide.