Multistate Tax Commission Adopts Amendments To Model General Allocation And Apportionment Regulations

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.

The U.S. Treasury Department and IRS have proposed sweeping regulations that would eliminate tax-exempt status for private schools engaging in any form of racial discrimination, including race-conscious admissions and scholarship programs previously permitted under safe harbor provisions. These proposed rules would affect approximately 18,000 private educational institutions and 750,000 students...