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Tax Law Update: September 2026

The most notable tax law developments of the past month

Transitioning Foreign Tax Allocations and Implementing the Ten Percent Credit Disallowance Under Section 960(d)(4)

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...

Latest Tax Updates: Section 7508A Refund Claims, Whistleblower Award Eligibility, and Court Restrictions on IRS Collecti...

Wealth Tax Watch- A Mid-Year Update

Tax Regulations Go Down: State Regulations May Also Tumble

Treasury’s Excluded Property Sales Income Regulations under Section 250: Deconstructing the Proposed Guidance for Tax Pr...

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....

Tax Law Update: July/August 2026

The most notable tax law developments of the past month

Pro Rata Share Determinations Under the One, Big, Beautiful Bill Act: Analysis of the Proposed Regulations

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...

Why Do I Owe Taxes To The IRS?

Updated for tax year 2026. You owe the IRS at tax time when your total tax for the year is […] The post Why Do I Owe Taxes To The IRS? appeared first on .

2025 State & Local Tax (SALT) Season Wrap-Up

Latest Tax Updates- IRS Launches Automatic Penalty Relief Program and Court Invalidates GILTI Rule

Crypto Tax in India 2026: Rules, Rates, Reporting & Penalties

In India, cryptocurrency can be bought, held, and traded legally, but a higher tax is levied on it, and the reporting rules are stringent. Buying, selling, or swapping crypto carri...

Foreign Tax Credits Against the Net Investment Income Tax: A Critical Analysis of the Federal Circuit’s Decisive Rulings...

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...

Immigration Status Restrictions on Refundable Individual Tax Credits: Analyzing the Preamble and Provisions of REG-11988...

Notice of Proposed Rulemaking, REG-119882-25, RIN 1545-BS06, ‘Application of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 to the Refunded Portion...

The Full Payment Requirement and the Presumption of Correctness: Jurisdictional Lessons from Pellegrino v. United States

Pellegrino v. United States, No. 1:26-cv-00403, 2026 WL (Fed. Cl. Aug. 20, 2026) In Pellegrino v. United States, No. 1:26-cv-00403 (Fed. Cl. Aug. 20, 2026), Judge Philip S....

Hidden Tax Trap: Does OBBBA Affect Trusts and Estate Deductions?

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...

Misclassified Tax Cannot Become A Lawful Levy: Limitation Cannot Validate An Unauthorised Tax Collection

Introduction The question of whether the Government can retain an amount collected as tax despite the absence of a lawful statutory liability has repeatedly arisen under the erstwh...

IRS Updates Business Interest Deduction Guidance Following Tax Law Changes

Revised FAQs for the business interest deduction explain changes to adjusted taxable income, floor plan financing, capitalization rules, and CFC inclusions.

Reevaluating the Section 163(j) Interest Expense Limitation: Technical Insights from IRS Fact Sheet FS-2026-14

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 Invalidity of the Extraordinary Disposition Rules: Tax Court Upholds the Plain Meaning of Section 245A in Siemens v....

Siemens Medical Solutions USA, Inc. & Consolidated Subsidiaries v. Commissioner, 167 T.C. No. 5 (2026) In Siemens Medical Solutions USA, Inc. and Consolidated Subsidiaries...

Analyzing the New Regulations on the Car Loan Interest Deduction: A Technical Guide for Tax Professionals

Car Loan Interest Deduction, T.D. 10054, 91 Fed. Reg. 18219 (scheduled for publication Sep. 8, 2026) The release of the final regulations under Treasury Decision (T.D.) 10054...

The Sunset Is Gone. Income Tax Remains: The PPLI – PPVA Solution.

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...

Harmonizing Section 3406 Backup Withholding with Section 6050W De Minimis Reporting Thresholds: An Analysis of the Final...

Backup Withholding on Third Party Network Transactions, T.D. 10053, 91 Fed. Reg. 16269 (Aug. 10, 2026) On August 10, 2026, the Department of the Treasury and the Internal Rev...

In the blogs: Ignorance of the law is no excuse

Taxes don't pause; chaotic policy; larger tax burden; and other highlights from our favorite tax bloggers.