Worldwide: Corporate Tax

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

A recent decision from the United States District Court for the Southern District of Florida offers a cautionary tale for estate planners who rely on Qualified Personal Residence Trusts (QPRTs) and the interplay between state homestead protections and federal estate tax inclusion rules.

The IRS has fundamentally transformed how it administers penalty relief for compliant taxpayers, replacing the decades-old First Time Abate program with an automatic system that eliminates the need for taxpayers to request relief they're entitled to receive.

A New York administrative law judge ruled that combined reporting groups must have each member independently qualify for the state's reduced qualified emerging technology company (QETC) franchise tax rate. The decision means that even one nonqualifying entity can prevent an entire combined group from receiving New York's preferential QETC tax treatment, creating significant implications for businesses with mixed-member combined filing structures.

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.

The US Court of Appeals for the Fifth Circuit has quietly rewritten the rules for who counts as a “limited partner” exempt from self-employment tax, replacing a taxpayer-friendly January opinion with a more restrictive standard that will make the exemption harder to claim for partners who are actively involved in running their businesses.

The U.S. Treasury Department and IRS have issued proposed regulations addressing two significant changes to the Internal Revenue Code made under the One Big Beautiful Bill Act: the allocation of foreign income taxes following the repeal of the one-month deferral election for controlled foreign corporations, and the new partial foreign tax credit disallowance on certain previously taxed earnings and profits distributions. These regulations introduce four new elections that provide taxpayers with greater flex

The IRS has released updated pension interest rates and August applicable federal rates while intensifying examinations of noncash charitable contributions. Recent Tax Court decisions have invalidated...

California cannabis operators face critical decisions about license structure following federal rescheduling, as the distinction between medical and adult-use designations now carries significant tax and compliance implications. New DCC regulations allow businesses to convert or split A/M licenses outside the annual renewal cycle, but success depends on supply-chain alignment, operational readiness, and genuine medical activity. Understanding when to restructure—and when to wait—requires careful