News & Analysis as of

Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Mayer Brown

Intégration fiscale : obligation de scinder en périodes d'imposition distinctes le premier exercice long de la société mère...

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Intégration fiscale : lorsqu'une société nouvellement créée, devenue mère d'un groupe fiscalement intégré, clôture son premier exercice postérieurement au 31 décembre de l'année suivant celle de sa création, les dispositions...more

Eversheds Sutherland (US) LLP

Additional Section 892 proposed regulations to provide transitional relief

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In December 2025, Treasury and the IRS issued proposed regulations under Code section 892 (Prior Proposed Regulations) addressing the taxation of foreign government investment income in the United States. Key provisions...more

Alston & Bird

Treasury and IRS Ease Reporting Requirements for Sales of Partnership Interests

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Our Federal & International Tax Group examines final regulations that relieve partnerships from the requirement to report a transferor’s share of hot assets and other items within a short time after a transfer of partnership...more

Kilpatrick

5 Key Takeaways | State and Local Tax Hot Topics: 2026 and Beyond

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Kilpatrick partners David Hughes and Jordan Goodman recently spoke at the annual AGN International “2026 Americas Regional Meeting.” Their presentation discussed “State and Local Tax Hot Topics: 2026 and Beyond.” David and...more

Eversheds Sutherland (US) LLP

Practical insights for global executives

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In our recent webinar on Wednesday, 3 June, we provided a high level overview of tax impatriation rules and considerations across key jurisdictions for tax professionals, private client advisers and global mobility...more

Morgan Lewis - ML Benefits

Designing Executive Loan Programs in the Context of Incentive Equity: Key Considerations and Practices

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Executive loan programs have become a popular strategic response to complex executive compensation demands in a competitive talent market. The use of loan programs in conjunction with incentive equity awards has also seen an...more

Freeman Law

Menge v. Commissioner, Tax Court Memo. 2026-41 | May 19, 2026 | Kerrigan, J. | Dkt. No. 18451-23L

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Taxpayer filed federal tax returns for tax years 2015 through 2018 but did not pay the taxes owed. The IRS issued a Notice of Intent to Levy, and taxpayer requested a Collection Due Process hearing....more

Husch Blackwell LLP

As U.S. Plug-In Solar Market Expands, So Do Tax Risks

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Plug-in solar systems (also known as balcony solar or apartment solar) have been legalized by seven states this year. This opens up new markets to the sellers of small solar panels, microinverters, and their related...more

Whiteford

COVID Relief Enforcement Is Not Over: Defending Against PPP Fraud Allegations and ERC Disallowances

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The Internal Revenue Service’s April 27, 2026, announcement of a streamlined process for filing Form 907 to extend the deadline on Employee Retention Credit (ERC) disallowance challenges was, on its surface, a procedural...more

Bennett Jones LLP

Transfer Pricing Rules in Canada - Considerations for the Life Sciences Industry

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On March 26, 2026, Canada's new transfer pricing rules received royal assent and will have a significant impact on multi-national enterprises (MNEs) in life sciences industries. The rules now focus on enumerated "economically...more

DLA Piper

Carried interest reform returns to Congress: Ending the Carried Interest Loophole Act

DLA Piper on

On April 16, 2026, Senators Ron Wyden (D-OR), Sheldon Whitehouse (D-RI), and Angus S. King Jr. (I-ME) introduced the Ending the Carried Interest Loophole Act (Bill). If enacted into law, the Bill would impact fund sponsors,...more

Katten Muchin Rosenman LLP

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

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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 planning ideas can enhance deal value and...more

White & Case LLP

Proposed Australian Capital Gains Tax changes for foreign residents

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In addition to the several new tax measures announced in the Australian Federal Budget handed down on 12 May 2026, the Treasurer reiterated his commitment to the previously announced significant non-resident Capital Gains Tax...more

A&O Shearman

Federal Tax Court: Does an earn-out linked to continued employment constitute a capital gain or employment income?

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On May 21, 2026, the Federal Tax Court (Bundesfinanzhof, BFH) published an important decision (BFH, decision dated March 3, 2026—IX R 1/25) on how to classify income from an earn-out that is tied to the continued employment...more

Morrison & Foerster LLP

News from German Transactions Practice

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In a recent decision (judgment of March 3, 2026 – IX R 1/25), the German Federal Fiscal Court (BFH) addressed the highly practical question of whether the capital gain of a shareholder, paid under the condition of his...more

Morrison & Foerster LLP

Neuigkeiten in der Transaktionspraxis

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Der BFH hat in einer aktuellen Entscheidung (Urteil v. 3. März 2026, IX R 1/25) zu der höchst praxisrelevanten Frage Stellung genommen, ob der Veräußerungsgewinn eines Gesellschafters, der unter der Voraussetzung seiner...more

Rivkin Radler LLP

Tax Considerations for Individuals Targeted by New York’s Assault on Real Property Ownership

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Last month, New York’s governor announced that the State’s FY 2027 budget will include the enactment of an annual surcharge on second homes in New York City that are valued at $5 million or more. Query how much greater the...more

International Lawyers Network

Establishing a Business Entity in Brazil (Updated)

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The two most common forms of legal entities incorporated in Brazil are the limited liability company (“Limitada”) and the corporation (“S.A.”). These are considered the most attractive types of companies given that they are...more

White & Case LLP

Internal Revenue Code Section 999: The obscure international boycott tax rules every taxpayer should know

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The intersection of tax and trade law has been in the news in recent months as businesses navigate changing tariff rules. We have written extensively about the cross-roads of tax law and tariffs. All this talk about tariffs...more

FBT Gibbons LLP

Tax Strategies for QSBS: Stacking and Staggering Section 1202 Exclusions

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Much has been written about IRC Section 1202. Section 1202 affords non-C corporation taxpayers who sell a corporation’s qualified small business stock (“QSBS” or “1202 Stock”) issued after July 4, 2025 (and who satisfied the...more

McDermott Will & Schulte

IRS roundup: May 1 – May 11, 2026

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The IRS Office of Chief Counsel issued Chief Counsel Advice 202618011, addressing whether a taxpayer can apply a revised cost allocation method under Treasury Regulation § 1.482-9 as a set-off in a transfer pricing context....more

Eversheds Sutherland (US) LLP

Significant Revenue Procedure offers flexibility in corporate letter rulings

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The IRS has taken oscillating positions on issuing corporate letter rulings on isolated issues in the context of a larger, integrated transaction. Since 2024, taxpayers have been required to request a letter ruling regarding...more

Rivkin Radler LLP

Observations on the Wealthy’s Change in Attitude Toward Taxes

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Perception of Taxes- Since I started practicing almost forty years ago, there have always been a relatively few well-to-do individuals for whom the payment of any taxes – whether personal or business – under any...more

Morgan Lewis

German Federal Fiscal Court Rules on ‘Passive Disjunction from German Taxation’ („passive Entstrickung“) in case of Changes to DTA

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In two similar cases involving a partnership (I R 41/22) and a corporation (I R 6/23), the German Federal Fiscal Court (BFH) decided whether the mere amendment or conclusion of a new Double Tax Agreement (DTA) can lead to an...more

Littler

Internal Revenue Service Publishes Final Rule for “No Tax on Tips” Deduction

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As previously reported, the so-called “One Big Beautiful Bill Act” (OBBBA) provides an income tax deduction for “qualified tips” received by individuals in occupations that customarily and regularly received tips on or before...more

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