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“It’s pretty clear these two things are potentially at odds,” said Matthew Gardner, senior fellow at the Institute on Taxation and Economic Policy. “The more Treasury tries to gut...
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance, REG-115145-25, July 31, 2026 The Department of the Treasury...
When Public Law 119-21, commonly referred to as the One Big Beautiful Bill Act (“OBBBA”), was signed into law last year, most families breathed a sigh of relief. The law made the d...
Pro Rata Share of Subpart F Income, Tested Income, or Tested Loss, REG-115646-25, 91 Fed. Reg. _____ (proposed Aug. 26, 2026) The Department of the Treasury and the Internal R...
IRS Fact Sheet FS-2026-14 (Aug. 19, 2026); Internal Revenue News Release IR-2026-94 (Aug. 19, 2026) On August 19, 2026, the Internal Revenue Service (IRS) released Fact Sheet...
The Treasury Department is eyeing tax alpha strategies, which largely deploy financial engineering to exploit various rules in the U.S. tax code.
Foreign Currency Gain or Loss of Controlled Foreign Corporations, REG-103844-26, 91 Fed. Reg. (proposed Aug. 14, 2026) On August 13, 2026, the Department of the Treasury and t...
The U.S. Treasury Department has expressed concern over a number of high-profile tax strategies touted by Wall Street that it says may be "too good to be true."
Taxpayers and tax pros have already dealt with many changes from the One Big Beautiful Bill Act on 2025 returns, but many provisions will be effective for the first time in 2026.
The department worries that some products, including Section 351 conversions and box spread ETFs, could be ripe for abuse. It is actively evaluating tools to address those concerns...
SIH Partners LLLP, Explorer Partner Corp., Tax Matters Partner v. Commissioner of Internal Revenue, 167 T.C. No. 8 (August 6, 2026) In the highly structured world of corporate...
Just six companies received $83 billion in federal income tax breaks in 2025, the latest evidence that corporate tax avoidance has been turbocharged by the 2025 Trump/GOP tax law....
It is no secret that States abhor the protections afforded companies by P.L. 86‑272—the federal provision that prevents States from imposing an income tax in certain circumstances....
Application of Section 250(b)(3)(A)(i)(VII) to Sales or Other Dispositions of Property, REG-117130-25, 91 Fed. Reg. _____ (proposed Aug. 20, 2026) (to be codified at 26 C.F.R....
The new public country-by-country reporting regimes adopted by the EU and Australia, and changes from the Financial Accounting Standards Board for financial accounts, are meant to...
In Apple Inc. and U.S. Subsidiaries v. Nebraska Department of Revenue, Case No. CI 24-4186 (Lancaster Cnty. Dist. Ct., July 13, 2026), a Nebraska district court reversed the Tax Co...
Estate of Paul Bruyea v. United States, F.4th , No. 25-1563, ECF No. 58 (Fed. Cir. Aug. 31, 2026), reversing Bruyea v. United States, 174 Fed. Cl. 238 (2024). Matthew Christ...
This is not a minor procedural tweak. It changes how penalty relief gets delivered to millions of taxpayers, and what we owe our clients as their advisors.
For the better part of a decade, every estate planning conversation my colleagues had with a high-net-worth family started with the same clock: the 2017 Tax Cuts and Jobs Act exemp...
The Tax Foundation uses and maintains a General Equilibrium Model, known as our Taxes and Growth (TAG) Model to simulate the effects of government tax and spending policies on the...
Introduces concept of Principal Purpose Test, treaty not to be used to grant benefit for double non taxation and treaty shopping
CBDT Mandates Upload of Foreign Assets and Income Data in AIS and Form 26AS Under AEOI The Central Board of Direct Taxes has issued a key order to bring offshore financial data...
"The top 1%, in fact, are in line to get $1 trillion in tax cuts from the law over a decade," Jon Whiten, deputy director of the nonpartisan Institute on Taxation and Economic Poli...
According to a recent analysis by the Institute on Taxation and Economic Policy (ITEP), companies avoided paying more than $200 billion in federal income tax in 2025.
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