Social Media Ideas for Tax Analyses

Technical Analysis of TD 10051: The Reclassification of Abusive CRAT Structures as Listed Transactions

TD 10051, July 9, 2026 The issuance of TD 10051, which finalizes the proposed rules set forth in REG-108761-22, represents a definitive strategic shift in the Internal Reven...

Three Questions to Ask About New Tax Transparency Regimes

The new data disclosures will draw significant attention in 2026 and beyond. However, because the data is rooted in financial accounting concepts, affected by timing issues, and sh...

Wealth Tax Watch- A Mid-Year Update

Section 1060 Allocations and the Cost Approach: Deconstructing the Cost Basis of Tangible Personal Property in the Alta...

Alta Wind I Owner Lessor C, et al. v. United States, Nos. 13-402, 13-917, 13-935, 13-972, 14-47, 14-93, 14-174, 14-175, 17-997 (Fed. Cl. July 8, 2026). In the complex arena...

Tax Planning for Carve-Out and Take-Private Transactions: Use of Selective Section 338 and/or 336 Elections

In carve-out transactions, especially in take-private transactions backed by private equity (PE), tax friction costs can often make or break a deal. By the same token, creative tax...

Tax as deal architecture

In divestitures, tax does more than optimize a chosen structure. Tax influences whether a deal perimeter, legal entity structure, diligence story and separation plan are workable.

The Soroban Capital Partners SECA Tax Controversy: Partnership Items, Functional Analysis, and Appellate Oral Arguments

Soroban Capital Partners LP v. Commissioner, 161 T.C. 310 (2023); Soroban Capital Partners LP v. Commissioner, T.C. Memo. 2025-52; Soroban Capital Partners LP v. Commissioner,...

Medicaid Gross Receipts, Cohan Estimations, and the Limits of Professional Reliance: A Technical Analysis of Branch v. C...

Branch v. Commissioner, T.C. Memo. 2026-51, Docket No. 7214-20 (Filed June 17, 2026) In Branch v. Commissioner, T.C. Memo. 2026-51, the United States Tax Court addressed sev...

Capital Contributions vs. Compensation: Analyzing Ownership and Taxability in Manufacturing Expansion Agreements

Thermal Circuits, Inc. v. Commissioner, T.C. Memo. 2026-29 (July 7, 2026) In the complex intersection of supply chain financing and tax characterization, the distinction betwe...

State-by-State Tax Expenditure Reports

Below is a list of tax expenditure reports published in the states.

National Tax Journal Publishes New Issue

The National Tax Journal has published volume 79, number 2 (March 2026): Zero Deng (Oregon State, Business) & Scott G. Rane (Florida, Business), The Foreign Market Effect and E...

What 250 Years of Tax History Reveal About the US Tax Code

Just as many parts of American life have transformed over the past 250 years, so too has the federal tax system. While most taxes levied in the 18th century are still levied in som...

Clouse et al.: California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits

In Tax Notes, Jim Clouse, Fabio Natalucci, Charles W. Calomiris, Kenneth Rosen, David Bank, and Maxwell Hall, have written a new piece, “California’s Billionaire Tax Act Threatens...

Tax Law Update: June 2026

The most notable tax law developments of the past month

Analysis of Collection Due Process and Reasonable Collection Potential in Tooke v. Commissioner

Tooke v. Commissioner, T.C. Memo. 2026-54, June 23, 2026 The United States Tax Court recently issued a memorandum opinion in Tooke v. Commissioner, T.C. Memo. 2026-54, providi...

The Application of New Section 68 to Trusts and Estates: Analyzing JCT Footnote 102 and Unresolved Ambiguities

IRC §68 as amended by the One Big Beautiful Bill Act, July 4, 2025 The One Big Beautiful Bill Act (OBBBA) fundamentally reshaped Section 68 by replacing the suspended Pease limitat...

2025 Trump Tax Law One Year In: Who Won, Who Lost, and What Comes Next

As the one-year anniversary approaches of President Trump signing the so-called “One Big Beautiful Bill Act” (OBBBA) into law on July 4, the Institute on Taxation and Economic Poli...

IRS Notice 2026-40: Comprehensive Analysis of Post-OBBBA Transitional Guidance on Qualified Opportunity Zones

Notice 2026-40, Internal Revenue Service (June 2026). For practitioners advising clients on Qualified Opportunity Zone (QOZ) investments under the Internal Revenue Code (the C...

The Eradication of the Five Percent Safe Harbor: Analyzing the Court’s Vacatur of IRS Notice 2025-42

Oregon Environmental Council v. Internal Revenue Service, No. 25-4400 (D.D.C. June 6, 2026) The landscape of clean energy tax planning underwent a seismic shift following th...

Roundup: The OBBBA, One Year Later

July 4 marks one year since the enactment of the One Big Beautiful Bill Act, and analysts across the tax policy spectrum are taking stock: who received tax relief (and how much), w...

NYSBATS Report on NYC’s Pied-à-Terre Tax

The Tax Section of the New York State Bar Association has published a new report, Report No. 1531, which concerns Article 30-C of the New York Tax Law (i.e., the pied-à-terre tax)...

LCCI session analyses proposed amendments in Finance Bill 2026

Taxation of Cryptocurrency Staking Rewards under Section 61

Alvie N. Paschall and Patricia C. Paschall v. Commissioner of Internal Revenue, T.C. Memo. 2026-46 (June 4, 2026) The litigation in Paschall v. Commissioner involves the tax t...

House Ways and Means Exploring Perceived Disparity in Sports Team Pay Deduction

Cady Stanton (Tax Analysts): W&M Exploring Perceived Disparity in Sports Team Pay Deduction The top House taxwriter said his committee is considering whether expanding an upcom...