Federal

Tax Deductions Drive Manufacturers to Revisit Facility Plans
Why QPP deductions are forcing a fresh look at facility ownership—lease, buy, or build?

Accelerated depreciation and industry-based tax incentives are nothing new from a tax policy perspective. First-year bonus depreciation, ranging from thirty percent to 100 percent, has existed in the Federal Tax Code for over twenty years. Congress has also routinely stepped in to provide tax deductions or credits to specific industries.… Read more »

Certainty by Design
A practical guide to prefiling agreements, closing agreements, private letter rulings, and tax opinions

Tax executives operate in a world where material transactions cannot wait for litigation to resolve interpretive uncertainty. The Internal Revenue Code is dense, dynamic, and increasingly shaped by subregulatory guidance and administrative interpretation. Although litigation remains the ultimate backstop, most public companies, private equity sponsors, and closely held businesses cannot… Read more »

The Price of Regulatory Certainty
How does regulatory maturity shape the pricing of transferable tax credits?

Prior to the Inflation Reduction Act (IRA) of 2022, transferability of federal tax credits was limited in scope and fragmented across a small portion of programs. Monetization typically occurred through complex partnership structures or tax equity financing. These structures required specialized investors, longer structuring timelines, and higher transaction costs. For… Read more »

Considerations in Tax Refund Litigation
Is refund litigation the path to releasing “stuck” refunds?

The Internal Revenue Service has seen unprecedented changes this year. Approximately 25,000 IRS employees—or twenty-five percent of its workforce—have accepted the deferred resignation or retired or were laid off.1 When we wrote this article in November, the federal government had been shut down for more than four weeks with only… Read more »

How the IRS May Do More With Less
As the IRS modernizes with AI and other tech, it faces funding cuts and shifting enforcement priorities

Facing ongoing budget constraints and a significant reduction in workforce, the Internal Revenue Service is changing its approach to taxpayer service, enforcement, and collections. Taxpayers and tax practitioners are seeing early signs of how the IRS is leveraging technology and data analytics as well as returning to some old practices… Read more »

OBBBA Modifications to US Taxation of International Income
Changes in the new law affect GILTI, foreign tax credits, and inventory sourcing rules, among other international tax provisions

The One Big Beautiful Bill Act (OBBBA), which was signed into law on July 4, has changed US taxation of multinational businesses. The most notable among these changes are various modifications that relate to the former global intangible low-taxed income (GILTI) regime enacted during the first Trump administration as part… Read more »

The One Big Beautiful Bill Act
Assessing the impact of new tax legislation on single-family offices and their stakeholders

In July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking the most comprehensive overhaul of US tax policy since the 2017 Tax Cuts and Jobs Act (TCJA). This landmark legislation brings significant changes with direct implications for single-family offices, high-net-worth investors, and closely… Read more »

The Fringe Benefit Rules Applicable to Protecting Executives
What security measures are excludable from executives’ income?

Since the 2024 murder of Brian Thompson, the CEO of UnitedHealth Group’s insurance division, employers are reexamining their corporate security policies, which are designed to protect employees, including executives, from harm. The law is clear that the value of personal protection benefits provided to employees may be excluded from income… Read more »

Planning for IRS Audits in an Era of Uncertainty
Using the economic substance doctrine as a general anti-abuse rule

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions.1 For example, last year, the IRS released Revenue Ruling 2024-14,2 establishing its position that the tax effect of certain related-party basis adjustment transactions should be disallowed under… Read more »

Transfer Pricing and Valuation in Financial Transactions
The impact of OECD and IRS guidance on credit rating, debt capacity, and interest rates

Business transactions such as mergers, acquisitions, and reorganizations often necessitate the pricing and valuation of financial transactions. Applying different standards may result in different pricing or valuation for the same financial transaction. Therefore, identifying the appropriate valuation standard is crucial. Companies must comply with ever-evolving financial and tax reporting requirements… Read more »