Intelligence

The Department of the Treasury and the Internal Revenue Service (IRS) recently issued guidance for employers on the credit for paid family and medical leave under Internal Revenue Code (IRC) Section 45S, as amended by the One, Big, Beautiful Bill Act (OBBBA). These agencies intend to publish proposed regulations concerning the guidance contained in their Notice 2026-28.

California Senate Bill 122 expands sales tax treatment to include certain prewritten computer software, whether downloaded, transferred electronically, or accessed remotely through SaaS platforms, effective January 1, 2027. This episode explores key exemptions, sourcing challenges, the $5 million threshold, and practical compliance steps for software providers and purchasers preparing their contracts and systems.

The U.S. tax landscape has undergone dramatic transformation since the Tax Cuts and Jobs Act of 2018, with evolving rules, expiring provisions, and major legislation during President Trump's second term. This analysis examines the six most significant tax developments of the past eight years, from historic estate tax exemption increases to the growing importance of international taxation, and explores what these changes mean for taxpayers, advisors, and business owners navigating today's more stable but sti

Canadians considering a permanent move to Florida face a complex web of tax, immigration, and legal requirements that go far beyond simply changing addresses. Understanding the proper sequence of steps—from managing Canadian departure tax and securing the right US visa to structuring Florida real estate ownership and establishing compliant estate planning documents—can mean the difference between a smooth transition and costly mistakes that take years to unwind.

Foreign owners of single-member U.S. limited liability companies often assume their entities are completely disregarded for tax purposes, but since 2017, these structures face significant reporting obligations...

The Treasury Department and IRS have issued Notice 2026-61, extending the phase-in of Section 871(m) withholding regulations on dividend equivalent payments until 2029. This marks the sixth extension over more than a decade, affecting non-delta-one transactions, qualified derivative dealers, and the qualified securities lender regime, while Treasury officials indicate forthcoming regulations may replace or supplement the current framework.