2020 Tax Forecast

A Connecticut Supreme Court decision demonstrates how a $13 million estate tax dispute reinforces a critical planning lesson: formal declarations of domicile carry limited weight when contradicted by an individual's actual living patterns. The case examines how spending more time in Connecticut than Florida, despite obtaining a Florida driver's license and voter registration, led to a substantial tax liability.

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...

The IRS has intensified scrutiny of partnership basis-shifting transactions that manipulate inside and outside basis rules to generate tax savings. While recent regulations were withdrawn under the Trump Administration, the agency maintains its position through Rev. Rul. 2024-14, which identifies three transaction types that fail the economic substance doctrine.

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.

Record settler violence in the West Bank has drawn unprecedented international sanctions from the UK, France, and nine EU states, while Israel's far-right coalition pushes settlement expansion ahead of October elections. With the Palestinian Authority weakened and the US notably restrained in its response, the escalating crisis threatens regional partnerships and marks a stark departure from the Oslo Accords signed thirty-three years ago this September.

President Trump's Executive Order 14421 declares a national emergency to secure the U.S. bulk-power system, imposing new restrictions on foreign-produced electric equipment that poses national security risks. The order prohibits certain imports and installations while directing the Department of Energy to identify and potentially replace existing vulnerable equipment already on the grid.

Health Canada has launched a public consultation on a proposed regulatory overhaul that would fundamentally transform how food packaging materials are evaluated and approved for use in Canada. The agency is considering implementing a mandatory notification system and potentially creating a binding positive list of approved substances, marking a significant departure from the current voluntary Letter of No Objection framework.

The Department of Energy has issued a request for information on implementing President Trump's Bulk-Power System Executive Order, which would prohibit imports and installation of certain foreign-produced electric equipment deemed a national security risk. The RFI seeks public input on critical implementation questions including equipment scope, foreign entity definitions, supply chain risk assessment, and how to address already-installed equipment. Comments are due October 9, 2026, providing stakeholders a

Canada maintains a sophisticated yet largely voluntary system for regulating food-contact materials, placing primary responsibility on industry to ensure packaging safety. While Health Canada offers Letters of No Objection (LONOs) as written assurances, this regulatory framework may soon shift toward a mandatory positive list approach, fundamentally changing how food packaging materials are assessed and approved in the Canadian market.

India hosts the 18th BRICS Summit in New Delhi this weekend, where member nations navigate competing priorities: Russia seeks to demonstrate global relevance despite Western isolation, China and India work to strengthen their diplomatic thaw, and New Delhi pushes for digital currency integration while avoiding a common BRICS currency. Can the bloc maintain unity amid Brazilian elections, the Iran war, economic pressures, and members' diverging relationships with the US and other Western powers?

Germany's Alternative for Germany (AfD) party achieved a historic victory in Saxony-Anhalt regional elections, winning nearly 44% of the vote and dealing a severe blow to the ruling Christian Democratic Union. The election results are creating political instability that could weaken Berlin's leadership role in the European Union and reshape the bloc's approach to critical trade, industrial policy, and China relations during a pivotal period for European policymaking.

Global sanctions enforcement intensifies as the US expands its economic pressure campaigns against Cuba, Iran, and Venezuela while the UK and EU strengthen their Russia sanctions frameworks. Meanwhile, China pushes back against US sanctions targeting its companies over alleged Iran ties, and a Dutch chipmaker faces asset freezes amid a complex ownership dispute involving Chinese courts.

The FCC has opened a public comment period on ensuring reliable spectrum access for commercial space launch and reentry operations, following a presidential directive that aims to support over 1,000 annual launches by 2030. With comments due in just 20 days, companies involved in launch operations, UAS/USV services, and incumbent spectrum users face a compressed timeline to shape the regulatory framework for this rapidly expanding industry.

Russia's Africa Corps successfully defended Niger's military junta from a coup attempt in August 2024, demonstrating Moscow's deepening security role in the Sahel region. This analysis examines how Russia's entrenchment as a regime protector complicates US counterterrorism objectives and critical mineral access strategies, while exposing the Alliance of Sahel States' inability to provide mutual defense without external support.