Worldwide: Tax Authorities

High-net-worth families are restructuring their family offices using the Lender model to qualify as separate trades or businesses for federal tax purposes. This strategic shift enables them to deduct investment-related expenses that were eliminated for individuals under the Tax Cuts and Jobs Act, creating significant tax efficiency opportunities through carefully designed management entities and allocation structures.

The Internal Revenue Service has launched a nationwide recruitment initiative to fill critical seasonal positions across the country through the end of July 2026.

In a detailed discussion of California tax apportionment law, tax practitioners examine the landmark Smithfield Foods case and its implications for agricultural business classification and alternative apportionment methods.

The Internal Revenue Service announced it would hold a hearing on June 18, 2026, regarding a petition to add methyl methacrylate-ethyl methacrylate-methacrylic acid copolymer in a styrene solution to the list of taxable substances under the Superfund excise tax. However, due to receiving no requests to testify or topic outlines by the deadline, the IRS has canceled the scheduled hearing.

New York City has proposed rules to implement a pied-à-terre tax surcharge on certain high-value residential properties (with a market value of $5 million or more) that do not serve as a primary residence.

The Investment Company Institute, the trade association representing more than $45 trillion in assets across mutual funds, ETFs, and other fund structures, has filed a comment letter with the United States Treasury...

Property owners in Westchester County face a rapidly approaching June 16, 2026 deadline to challenge their 2026 tax year assessments, with twenty-two of thirty assessing jurisdictions sharing this critical date.

Many organizations are preparing to enter new markets or support remote talent in 2026. This shift can introduce new tax, payroll, and compliance responsibilities.

Federal courts are divided on whether the "limited partner exception" from self-employment tax applies only to passive investors or extends to all partners in limited partnerships with limited liability. With appeals pending in multiple circuits and the Fifth Circuit rejecting the Tax Court's functional analysis approach, the resolution of this controversy will significantly impact fund managers, professional service partnerships, and other passthrough business owners.