2018 Charitable Gifts

On Sept. 10, 2026, the California Department of Tax and Fee Administration (CDTFA) held its second Interested Parties Meeting to discuss proposed emergency regulations implementing state Senate Bill 122...

Pennsylvania's Department of Revenue has eliminated a key safe harbor for consolidated filers, requiring separate-company calculations of federal interest expense limitations under IRC Section 163(j) for Corporate Net Income Tax purposes starting in 2025. The new guidance introduces complex tracking requirements for intercompany interest, third-party debt, and carryforwards while freezing conformity to pre-OBBB rules, creating significant compliance challenges for multistate corporations.

The IRS has issued Notice 2026-40 providing transition guidance for investors who deferred capital gains under the original Opportunity Zone program. While December 31, 2026 remains the mandatory recognition date for deferred gains, the guidance reveals a potential planning opportunity that may allow certain investors to continue deferring gains under the new Opportunity Zone regime through strategic pre-year-end transactions.

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.

Greenberg Traurig's State and Local Tax team is hitting the road this fall with a packed schedule of speaking engagements at premier tax conferences across the country. From the COST Annual Meeting in San Antonio to the Hartman SALT Forum in Nashville, GT attorneys will address critical topics including legislative updates, apportionment issues, property tax developments, and multistate planning strategies that are shaping the state tax landscape.

Private placement life insurance (PPLI) has been characterized as a tax loophole for the ultra-wealthy, but is that characterization accurate? This analysis examines the mechanics, regulatory framework, and evolving accessibility of PPLI, challenging common misconceptions about how these insurance products actually work and who can benefit from them.

The U.S. Department of the Treasury and IRS have released Notice 2026-53, establishing new emissions rate tables for the Section 45Z clean fuel production tax credit and implementing key amendments from the One Big Beautiful Bill Act. The notice introduces distinct emissions rates for transportation fuels derived from animal manure, permits farm-specific alternative fate determinations, and addresses the exclusion of indirect land use change emissions.

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.

Washington voters will decide the future of the state’s new 9.9% tax on annual taxable income above $1 million after a repeal initiative qualified for the November ballot.

The IRS and Treasury Department have proposed sweeping new regulations that could strip tax-exempt status from private schools using race-based criteria in admissions, scholarships, or programs—even when designed to promote diversity or remedy historical discrimination. These proposed rules would affect an estimated 18,000 educational institutions nationwide and create significant compliance challenges for schools, their donors, and holders of tax-exempt bonds financing educational facilities.

Paul Bain has completed the second edition of Art Law: Cases and Controversies, a comprehensive legal guide published by LexisNexis that examines the intricate legal frameworks governing art creation, transactions, collecting, and preservation. The publication features contributions from leading professionals and addresses how traditional art law principles intersect with modern challenges posed by the Internet and artificial intelligence technologies.

Healthcare providers face inevitable overpayments from CMS, but the consequences of mishandling them can be severe. The Centers for Medicare & Medicaid Services recently updated its 60-Day Rule, fundamentally changing how providers must identify and return overpayments to avoid False Claims Act liability and substantial penalties.

The FDA's rescheduling of marijuana from Schedule I to Schedule III signals accepted medical use and lower abuse potential, creating new opportunities for business consolidation. As pharmaceutical and agricultural firms eye the cannabis industry, companies must strategically position themselves as either consolidators or attractive acquisition targets in this evolving landscape.

Artificial intelligence has revolutionized innovation at unprecedented speed, but its rapid advancement raises critical questions about intellectual property rights. Is AI a transformative tool that lawfully builds on existing knowledge, or does it systematically infringe on the creative works and patents of inventors and artists? The answer depends on which side of this intensifying legal debate you occupy.

LOI drift occurs when terms agreed to in a letter of intent fail to appear in the definitive agreement, creating costly gaps between the deal parties thought they closed and the contract that actually governs their relationship. A recent North Carolina case demonstrates how healthcare organizations can lose critical business understandings—from co-branding commitments to governance rights—when LOI terms aren't carefully tracked and incorporated into final agreements.

The Michigan Court of Appeals recently clarified an important distinction in legal precedent: published decisions issued before November 1, 1990, while not mandatory under MCR 7.215(J)(1), remain binding precedential authority under stare decisis principles. This guidance addresses a common misconception among practitioners who may undervalue older published opinions compared to newer unpublished ones, when in fact the opposite is true under Michigan court rules.

The Canadian Securities Administrators have introduced a new electronic access framework for continuous disclosure documents, allowing reporting issuers to satisfy delivery obligations through SEDAR+ rather than traditional mailing methods. This voluntary regime, effective September 22, 2026, requires issuers to meet specific filing...

When investors poured millions into an aircraft venture only to discover their brokers had diverted funds and concealed critical information, the path to recovery proved far more complex than simply proving fraud. This case reveals how commercial fraud often emerges not from elaborate schemes but from legitimate ventures under pressure, and why identifying all parties with potential liability—including seemingly innocent intermediaries—can mean the difference between a worthless judgment and act

The U.S. Patent and Trademark Office has undergone significant reforms that fundamentally alter how patent challenges are reviewed and decided. With Director John Squires reclaiming direct authority over inter partes review proceedings and new proposed rules limiting repeat challenges, the patent system is shifting toward greater stability and predictability for inventors and patent owners.

State regulators are intensifying scrutiny of digital goods marketing practices, particularly whether consumers understand the difference between purchasing ownership rights versus acquiring limited licenses. As major game publishers shift away from physical media toward digital-only distribution, lawmakers in California, Maryland, New York, and other states are proposing legislation requiring clearer disclosures about what consumers actually receive when they click "buy."