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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.
Mayer Brown

OECD Pillar Two Side-by-Side System and New Safe Harbors

Mayer Brown on

On January 5, 2026, the Organisation for Economic Co-operation and Development (“OECD”) announced that the Inclusive Framework on Base Erosion and Profit Shifting agreed to a new package of administrative guidance (the...more

Foley Hoag LLP - Cannabis and the Law

New Jersey Legislative Changes Implement Growth and Opportunity for Cannabis Marketplace

As 2025 ended and 2026 commenced with a flurry of legislative activity in New Jersey touching on cannabis businesses. These changes, as a whole, impact several material changes to the marketplace, including: (a) increasing...more

A&O Shearman

Italy’s 2026 Budget Law: practical takeaways for businesses

A&O Shearman on

The 2026 Italian Budget Law was published in the Italian Official Gazette on December 31, 2025. It introduces significant changes to Italy’s tax framework with material implications for investors, financial intermediaries,...more

Holland & Knight LLP

Revisión del Régimen Presencia Económica Significativa en Colombia

Holland & Knight LLP on

Tradicionalmente, conforme a lo dispuesto en los artículos 24 y 408 del Estatuto Tributario (ET), en materia de servicios, solo se consideran ingresos de fuente nacional aquellos derivados de los que son prestados en...more

Holland & Knight LLP

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review and Implications

Holland & Knight LLP on

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework) on January 5, 2026, released its Side-by-Side (SbS) Safe Harbor package (SbS Package) to streamline Pillar Two's...more

Pullman & Comley, LLC

Understanding Section 409A and Its Implications for Employers and Employment Agreements

Pullman & Comley, LLC on

Prior to the enactment of Section 409A, no single section of the Internal Revenue Code governed taxation of nonqualified deferred compensation.  Income inclusion of deferred compensation was historically governed by a variety...more

McDermott Will & Schulte

Nuclear power projects gain momentum as federal tax incentives, data center demand transform financing landscape

With electricity demand rising across the United States, nuclear power is receiving renewed attention from energy developers, investors, and financiers – both for existing facilities and new projects....more

Husch Blackwell LLP

Hydrogen Used to Power Data Centers Is Taxable in Texas

Husch Blackwell LLP on

Investment in data centers continues to increase significantly as the country builds out infrastructure to accommodate the digital economy and growth of artificial intelligence. Many states, including Texas, have now...more

Goodwin

Unlocking the UPREIT Structure: A Comprehensive Guide to LTIP Units as Currency for Incentive Equity Awards

Goodwin on

The umbrella partnership real estate investment trust (“UPREIT”) structure, a cornerstone of the modern REIT industry, provides REITs with powerful tools for both property acquisitions and executive compensation. ...more

Schwabe, Williamson & Wyatt PC

IRS Final Rule on Tribal General Welfare Benefits: What It Means for ANCs and Tribal Governments

On December 16, 2025, the Internal Revenue Service issued a Final Rule implementing section 139E-1 of the Internal Revenue Code and the Tribal General Welfare Exclusion Act of 2014. The rule governs when benefits provided...more

Goodwin

Deadlines Approaching for Reporting 2025 ISO Exercises and ESPP Share Transfers

Goodwin on

The Internal Revenue Code (the Code), as amended, requires corporations to provide information statements to employees (including former employees) and information filings to the IRS regarding employees’ and former employees’...more

Bricker Graydon LLP

Foreign Entity of Concern Rules: A Quick Overview for Clean Energy Stakeholders

Bricker Graydon LLP on

The clean energy industry is at a crossroads. The One Big Beautiful Bill Act (OBBBA) introduced sweeping restrictions on Foreign Entities of Concern (FEOCs), fundamentally changing how developers, manufacturers, and investors...more

Williams Mullen

Estate Tax Portability: Tax Court Emphasizes Importance of Proper Filing

Williams Mullen on

In Estate of Rowland v. Commissioner, the Tax Court held that estate tax returns filed solely to elect portability must still be complete and properly prepared. Even when no estate tax is owed, missing asset-level information...more

Kilpatrick

Updated Special Tax Notices for Retirement Plan Distributions

Kilpatrick on

On January 15, 2026, the IRS and Treasury issued Notice 2026-13, which updated the guidance available to plan administrators tasked with providing rollover notices and safe harbor special tax notices designed to comply with...more

Pillsbury - Propel

USPS Postmark Rule Change: Implications for Section 83(b) Elections

Pillsbury - Propel on

For startup founders seeking to reduce their potential tax exposure through a Section 83(b) election, timing matters. ...more

Polsinelli

IRS Signals Continued Enforcement With New Conservation Easement Settlement Offer

Polsinelli on

The Internal Revenue Service has announced plans to roll out a new settlement initiative aimed at reducing the significant backlog of conservation easement cases currently pending before the U.S. Tax Court and the examination...more

Pillsbury - SeeSalt Blog

No Contract, No Look-Through: Wisconsin Draws a Line on Software Receipts Sourcing

In a recent decision, the Wisconsin Tax Appeals Commission drew a bright line for sourcing receipts from software for sales factor apportionment purposes: without a contract with the end-user, a company cannot source receipts...more

Pillsbury Winthrop Shaw Pittman LLP

New Year, New Benefits: Trump Accounts Offer a New Opportunity for Employer-Sponsored Benefits

Trump Accounts are a new, tax-favored savings vehicle for minors created under the One, Big, Beautiful Bill Act....more

Baker Donelson

Tennessee Department of Revenue Rules Bitcoin Teller Machines Exempt from Tennessee Business Tax

Baker Donelson on

In late December 2025, the Tennessee Department of Revenue (the Department) posted Revenue Ruling #25-10, which concluded that the Tennessee business tax does not apply to Bitcoin teller machines, citing Business Tax...more

Saul Ewing LLP

Creating and Preserving Non-Grantor Status in Spousal Trusts

Saul Ewing LLP on

A spousal lifetime access non-grantor trust (often referred to as a "SLANT") is an irrevocable trust structured to benefit the donor's spouse, while avoiding grantor trust treatment for income tax purposes. The structure is...more

FBT Gibbons LLP

NYSDEC Finalizes Important Amendments to Its Brownfield and Superfund Regulations

FBT Gibbons LLP on

On December 31, 2025, the New York State Department of Environmental Conservation (NYSDEC) finalized important amendments to the regulations that implement its remedial programs, including the Brownfield Cleanup Program (BCP)...more

Cooley LLP

Capital Markets Update – January 2026 One-Minute Reads

Cooley LLP on

Buried inside the annual defense spending bill, the National Defense Authorization Act, is the “Holding Foreign Insiders Accountable Act,” which was signed into law by President Donald Trump on December 18, 2025....more

Cooley LLP

California’s Proposed ‘Billionaire Tax’: Nine Things to Know

Cooley LLP on

A proposed California ballot initiative – “The 2026 Billionaire Tax Act” (also known as Initiative 25-0024) – has been getting a lot of attention, and it could have implications for business valuations, capital structures and...more

Spilman Thomas & Battle, PLLC

The Dome Report: A Fast Start for the West Virginia Legislature in 2026

The West Virginia Legislature started its 60-day regular session on January 14, 2026 at breakneck speed with a total of 565 bills – 306 in the House and 238 in the Senate – introduced on the first day and with new leadership...more

Perkins Coie

Water District’s Groundwater Replenishment Charges were Unconstitutional Taxes Under Proposition 26

Perkins Coie on

The Court of Appeal affirmed rulings that a water district’s groundwater replenishment charges were unconstitutional “taxes” because the District failed to prove the cost-allocation requirement of Proposition 26’s...more

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