Worldwide: Income Tax

Recent court decisions interpreting COVID-19 disaster period tax law may entitle tens of millions of taxpayers to refunds or abatements of federal penalties and interest assessed during 2020-2023.

Portability of estate and gift tax enables a surviving spouse to inherit any unused portion of their deceased spouse's federal estate and gift tax exemption, potentially doubling the exemption amount. While this powerful mechanism can help married couples preserve unused tax exemptions and minimize transfer tax liability, it is frequently misunderstood, underutilized, or improperly elected. Understanding the statutory framework, mechanics...

Employers continue to receive pitches for wellness and medical indemnity programs promising significant payroll tax savings, but recent IRS guidance makes clear these arrangements...

The U.S. Treasury Department and IRS have issued new proposed regulations addressing transition relief and grandfathering provisions for foreign government investors under Section 892.

The IRS and Treasury have released new proposed regulations under Section 892, revising applicability dates for previously proposed rules from 2025 that govern debt acquisitions and the "effective control" standard for foreign government investments. These revised dates include transition rules designed to protect existing and committed investments from the more stringent 2025 standards, while the preamble signals potential substantive changes to address market concerns.

The Internal Revenue Service has reported significant enrollment in Trump Accounts, a new tax-advantaged retirement savings vehicle for children established under the One Big Beautiful Bill.

April 2026 marks the 10th anniversary of the Panama Papers, one of the largest data leaks in history. The leak exposed how wealthy individuals and entities used offshore shell companies, trusts, and other structures for secrecy, tax planning, and potential IRS tax evasion.

Section 1202 of the Internal Revenue Code offers substantial tax benefits for qualified small business stock (QSBS) holders, allowing exclusion of gains up to $10 million or more per taxpayer. Strategic gifting of QSBS shares to family members, trusts, and other entities can multiply these exclusions, potentially sheltering tens of millions in capital gains from federal taxation while navigating complex timing, gift tax, and trust structure considerations.

The One Big Beautiful Bill Act (OBBBA) introduced a new federal income tax deduction for certain overtime compensation for tax years 2025 through 2028.