IRS Provides Relief For Section 163(j) Elections

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.

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.

The Treasury Department and IRS have released Notice 2026-48, providing the first comprehensive guidance on SECURE 2.0's new Saver's Match program. This federal matching contribution for low- and moderate-income retirement savers introduces complex implementation challenges, including how to route taxpayer matches directly to retirement plans and IRAs. The Notice addresses eligibility requirements, income limits, contribution types, and delivery mechanisms while requesting public comments on operational app

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...

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.

On August 6, 2026, the IRS released Fact Sheet 2026-13, an expanded set of FAQs on the qualified overtime compensation deduction created by the One, Big Beautiful Bill Act. The update replaces January’s FS-2026-01 and marks the shift from 2025’s transition relief to the full compliance framework now in effect.

California is implementing a major tax policy shift that will subject software-as-a-service, remotely accessed software, and digital products to sales and use tax beginning January 1, 2027. The California Department of Tax and Fee Administration has proposed emergency regulations establishing sourcing rules, a $5 million threshold that shifts tax liability from retailers to purchasers, and key exemptions for custom software and certain service-based digital products.

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...

On August 6, 2026, the IRS released Fact Sheet 2026-13, an expanded set of FAQs on the qualified overtime compensation deduction created by the One, Big Beautiful Bill Act. The update replaces January’s FS-2026-01 and marks the shift from 2025’s transition relief to the full compliance framework now in effect.

Last week, the Louisiana Department of Revenue (the "Department") issued guidance regarding recent sales and use tax law changes. The Department issued Revenue Information Bulletin No. 25-023...

The Second Circuit has affirmed the Tax Court’s rulings against Soroban Capital Partners LP, holding that the firm’s three principals were not “limited partners” for purposes of the self-employment tax exclusion found in I.R.C. § 1402(a)(13), despite formally holding limited partner status under Delaware law. Under the Internal Revenue Code, a partner’s distributive share of partnership income is generally treated as self-employment income subject to the 15.3 percent self-employment tax on income up to $184,500 in 2026 (2.9 percent rate above that threshold), which funds Social Security and Medicare. Section 1402(a)(13), however, excludes from that tax the distributive share of a “limited partner, as such,” other than guaranteed payments for services rendered.

The Treasury Department and IRS issued final regulations implementing the new deduction for qualified passenger vehicle loan interest (QPVLI), a temporary benefit created by the One, Big, Beautiful Bill Act (OBBBA) that allows individuals to deduct up to $10,000 of interest paid on certain auto loans, even if they do not itemize deductions. The final rules largely adopt the proposed regulations issued in January 2026 but include clarifications in response to public comments received by the Treasury Department.

The Investment Company Institute, the trade association representing more than $45 trillion in assets across mutual funds, ETFs, and other fund structures, has filed a comment letter with the United States Treasury...

The Internal Revenue Service ("IRS") announced a new electronic filing platform for Form 15620 to make an election pursuant to Section 83(b) of the Tax Code.

The City of New Orleans Department of Finance has launched a Sales Tax Amnesty Program offering businesses a limited-time opportunity to settle overdue sales tax obligations with significant penalty relief. Through December 31, 2026, qualifying taxpayers can resolve delinquent balances for sales taxes, use taxes, hotel/motel taxes, and other municipal taxes while having all penalties, negligence fees, and half of accrued interest waived.

The Treasury Department and IRS issued proposed regulations providing guidance on the new Federal Scholarship Tax Credit, effective in 2027. The credit is designed to encourage contributions to scholarship granting organizations (“SGOs”) that provide financial assistance for eligible K-12 students.

For owners of closely held businesses, an employee stock ownership plan, or ESOP, can be an attractive way to transition ownership while allowing employees to participate in future growth. But one issue has long made ESOP transactions more difficult and expensive: uncertainty over how the Department of Labor, or DOL, and courts will evaluate the price paid for privately held employer stock.

On August 28, 2026, the Maritime Administration (MARAD) published an interim final rule rewriting the regulations governing the Vessel and Shipyard Financing Program, commonly known as the Title XI Program, found at 46 CFR Part 298. The rule took effect immediately upon publication, though MARAD is accepting public comments through October 27, 2026.