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Orrick, Herrington & Sutcliffe LLP

Risk and Reward: How Starting Your Business as an LLC Could Impact QSBS Tax Savings (UPDATE)

As a founder, deciding whether to organize your business as a corporation or a limited liability company (LLC) is a crucial first step. Corporations are often favored for their ability to attract venture capital and offer...more

Morgan Lewis

Final US Postal Service Rules on Postmarks May Complicate Taxpayer Filings for Some Filers

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Recently finalized rules from the United States Postal Service seek to clarify that the date on a postmark does not “necessarily represent either the place at which, or the date on which, the Postal Service first accepted...more

McDermott Will & Schulte

IRS roundup: December 12, 2025 – January 12, 2026

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for December 12, 2025 – January 12, 2026....more

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2026

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This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code (IRC) of 1986, as amended, with respect to: Incentive stock option (ISO) exercises by current...more

Fox Rothschild LLP

Maine Opens Door to Tribal Internet Gaming

Fox Rothschild LLP on

Maine will soon offer internet gaming, with a focus on creating economic opportunities for the Wabanaki Nations and other federally recognized tribes in the state. More than a year after the Legislature introduced a...more

Eversheds Sutherland (US) LLP

IRS provides new option for navigating differences between customs and transfer pricing values

As tariffs on goods imported into the United States keep changing, the interplay between customs values and transfer pricing has become more significant. Taxpayers with established transfer prices may be incentivized to seek...more

Winstead PC

Texas Real Estate: A Strategic Entry Point for Mexican Investors

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Texas continues to stand out as one of the most attractive U.S. real estate markets for Mexican investors seeking scale, stability, and long-term value. With its strong economic fundamentals, business-friendly legal...more

Bennett Jones LLP

Comply or Lose Your Tax Deductions: New Income Tax Act Rules Target Short-Term Rental Landlords

Bennett Jones LLP on

Much like any other business, owning and managing short-term rental property is subject to provincial and municipal regulatory regimes....more

Dentons

First Day of the 2026 Iowa Legislative Session

Dentons on

The first day featured leadership speeches and procedural business. Speeches from Iowa governmental leaders will continue, and major highlights and takeaways will be published in our legislative update at the end of the week....more

Foley & Lardner LLP

Recent IRS Guidance on Branch Profits Tax Treaty Benefits for Foreign Reverse Hybrid Entities

Foley & Lardner LLP on

The IRS recently issued a Chief Counsel Advice Memorandum (AM 2025-002) (the CCA) that provides helpful guidance regarding the application of the branch profits tax (BPT) in connection with reverse foreign hybrid (RFH)...more

Mayer Brown

Capital Markets Insight: Reincorporation Considerations

Mayer Brown on

Since mid-2024, the reincorporation of certain high-profile companies, both public and private, has received a great deal of media attention. Companies, including, among others, Roblox, Dropbox, The Trade Desk, Simon Property...more

Skadden, Arps, Slate, Meagher & Flom LLP

Regulatory/Enforcement

Turbulence Ahead: Tariff and Trade Policy Shifts Are Expected Amid Looming Supreme Court Decision. Political Law Due Diligence in M&A Transactions Is Increasingly Critical....more

McDermott+

Healthcare Preview for the Week of: January 12, 2026

McDermott+ on

Last week, the House passed a three-year clean extension of the enhanced advanced premium tax credits (APTCs), which expired December 31, 2025. While 17 Republicans supported the bill, it appears to be dead on arrival in the...more

Eversheds Sutherland (US) LLP

What a relief: OECD releases Pillar Two Side-by-Side Package

On January 5, 2026, the OECD published the Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (side-by-side package), following months of negotiations. The side-by-side package extends and introduces new...more

Paul Hastings LLP

Senate Advances Market Structure Markup and Wyoming Launches FRNT Stable Token

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The Senate Banking Committee is targeting Jan. 15 for the committee to mark up its portion of the digital asset market structure legislation. In anticipation of the markup, Senate Banking Republicans circulated a proposal to...more

Eversheds Sutherland (US) LLP

Stamp to confirm your filing date: New postal regulation reinforces best practices in tax controversies

Effective December 24, 2025, the US Postal Service (USPS) implemented a new rule that fundamentally changes how postmarks are defined under the Internal Revenue Code’s so-called “mailbox rule.” Section 7502 provides a...more

Falcon Rappaport & Berkman LLP

Enforcement Date Approaches for Inherited IRA Beneficiaries

A recent WSJ article highlights a critical alert for beneficiaries who inherited traditional IRAs after 2019: the window to take distributions is limited and time-sensitive. Under the post-SECURE Act guidance from the...more

Houston Harbaugh, P.C.

A Charge to Everyone

Houston Harbaugh, P.C. on

In Part 1 of this series, we broadly examined the background to the stormwater fees that many Pennsylvania property owners are being assessed. We also briefly evaluated the Borough of West Chester case, currently on appeal at...more

Sheppard Mullin Richter & Hampton LLP

Reminder about Annual ISO/ESPP Reporting in January 2026

As originally discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require employers to annually furnish each employee who...more

McDermott Will & Schulte

Neuere Entwicklungen im Steuerrecht - Neues zu gewerblichen Personengesellschaften

Die Obersten Finanzbehörden der Länder haben mit gleich lautendem Erlassen vom 5.11.2025 ihre vorherige Auffassung aufgegeben, dass eine nicht gewerbliche Per-sonengesellschaft allein deshalb der Gewerbesteuer unter-liegt,...more

McDermott Will & Schulte

IRS releases final and proposed regulations affecting the taxation of foreign governments

On December 15, 2025, the US Department of the Treasury and the Internal Revenue Service (IRS) published final regulations and proposed regulations under Section 892 of the Internal Revenue Code relating to the taxation of...more

Skadden, Arps, Slate, Meagher & Flom LLP

OECD Publishes Pillar Two Global Minimum Tax Safe Harbor, Benefitting MNE Groups With Ultimate Parent Entities Located in the U.S.

On January 5, 2026, the Organisation for Economic Co-operation and Development (OECD) released a long-awaited package of administrative guidance which introduces a number of new safe harbors within the Pillar Two Global...more

Bradley Arant Boult Cummings LLP

Alabama Mobile Workforce Legislation Goes Live - SALT Alert: Alabama Edition

Because the remote workforce has now become a fixture of the modern economy, providing a uniform safe harbor to ease the compliance burdens on both traveling employees and their employers, when those employees travel for work...more

Holland & Knight LLP

Tax and Legal Planning for the Venezuelan Diaspora in Transition

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For a quarter of a century, the Venezuelan people have faced profound economic, social and institutional disruptions. For many high-net-worth families, these circumstances have meant not only the fragmentation of assets and...more

Holland & Knight LLP

What to Watch for as Washington State Crafts a Millionaire's Tax

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Entering 2026, Washington joins the growing list of states looking to implement new taxes on the "rich" – those earning more than $1 million per year. In December 2025, Gov. Bob Ferguson signaled his approval for a new 9.9...more

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