IRS Issues Regulations On Disguised Sale Rules

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.

Recent federal legislation has permanently extended the historically high unified exemption amount for federal estate and gift tax purposes. The current exemption of $13.99 million per individual remains in place through December 31, 2025...

California's Proposition 40 would impose a one-time excise tax of up to 5 percent on billionaires' worldwide net worth, measured as of December 31, 2026, but based on residency as of January 1, 2026. The measure faces significant legal challenges and could be nullified by competing ballot initiatives that have also qualified for the November 2026 ballot.

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.

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

Among the many changes included in the One Big Beautiful Bill Act (OBBBA) is one relevant to brands and agencies running sweepstakes, contests, and other consumer promotions.

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.

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 US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.

On September 3, 2026, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations under Section 501(c)(3) that could materially affect private education in the United States. The proposal would apply a broad nondiscrimination standard based on race, color and national or ethnic origin, with significant implications for private schools, colleges and universities seeking or maintaining tax-exempt status under Section 501(c)(3).

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).

Medicare Advantage faces unprecedented regulatory scrutiny as federal agencies deploy aggressive audit strategies, Congress investigates alleged fraud schemes, and courts challenge CMS's authority over payment structures.

The U.S. Department of Labor's Wage and Hour Division has withdrawn its controversial proposal to remove nine parts of longstanding Fair Labor Standards Act interpretive guidance from the Code of Federal Regulations. What does this reversal mean for employers who have relied on these decades-old interpretations, and how does the Supreme Court's Loper Bright decision reshape the legal weight of agency guidance going forward?

In a landmark decision, a nine judge bench of the Supreme Court of India ruled today that privacy is a fundamental right protected by the Constitution of India.

The European Parliament's Committee on Economic and Monetary Affairs has adopted its position on the Sustainable Finance Disclosure Regulation reform, establishing key divergences with the European Commission and Council on professional investor exemptions and fossil fuel investment criteria. With trilogue negotiations set to begin in October 2026, private markets managers face critical decisions about how to position their funds under the new three-category framework expected to take effect in early 2029.

Recent California and federal court decisions address critical employment law issues including the extraterritorial application of California labor statutes, mass joinder in workplace harassment cases...

The CFTC has proposed classifying event contracts as swaps while excluding traditional casino-style gambling products, directly responding to ongoing federal-state disputes over prediction markets and sports betting jurisdiction. These regulatory actions seek to clarify the agency's authority over event contracts amid conflicting appellate court decisions and pending Supreme Court review.

The Second Circuit Court of Appeals has rejected the NLRB's Tesla standard for evaluating workplace dress code policies, finding it fails to properly balance worker and employer interests. The court vacated the Board's decision against Starbucks and suggested a new three-factor test rooted in the traditional "special circumstances" framework.

The Department of Justice has operationalized its fraud-enforcement architecture through data analytics, targeting healthcare providers with multi-district strike forces, Medicare Advantage risk-adjustment actions, and accelerated qui tam review processes. How are federal and state agencies using publicly available data to drive False Claims Act enforcement, and what proactive steps should healthcare organizations take to identify and remediate potential exposure before becoming the focus of government atte

The August 2026 Section 7520 rate remains at 5.20% for estate planning techniques. Treasury Decision 10051 targets CRAT abuse schemes as listed transactions requiring disclosure. New guidance addresses Trump Account contributions, charitable LLC arrangements face IRS scrutiny, and Florida introduces streamlined trustee discharge procedures.