Is ICAP A Viable Alternative To APAs?

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...

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.

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.

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.

New York's groundbreaking pied-à-terre tax takes effect July 1, 2026, imposing substantial surcharges on non-resident luxury second homes valued over $5 million. With a complex two-phase implementation, aggressive compliance deadlines, and penalties up to 50% for documentation errors, property owners face critical decisions about exemption eligibility and appeal strategies. Understanding the valuation methodologies, primary residence requirements, and procedural pathways is essential for high-net-worth

The Treasury Department and IRS have proposed new regulations that would establish an explicit racial nondiscrimination requirement for private schools seeking federal tax exemption under Section 501(c)(3). These proposed rules go beyond existing law by prohibiting all forms of racial discrimination in education regardless of intent, legality, or purpose, potentially affecting admissions policies, scholarship programs, and other school-administered initiatives.

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.

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.

Selling a Florida condo, an Arizona vacation home or a New York rental as a Canadian? Before the closing wires hit your account, the IRS may already have 15 percent of the gross sale price.

The United States Attorney's office for the Southern District of New York announced last week charges against Gal Luft, a dual U.S.-Israeli Citizen, for willfully failing to register...

Earlier this month, an indictment was unsealed in the Southern District of Texas charging Congressman Henry Cuellar and his wife, Imelda, with participating in schemes involving bribery...

In a reviewed opinion, Valley Park Ranch,[1] the Tax Court thoughtfully reconsidered its position on the validity of the so-called "proceeds regulation", Treas. Reg. § 1.170A-14(g)(6)(ii)...

On July 30, 2013, the District of Columbia retroactively repealed the provision that would have subjected most tax-exempt bonds owned by D.C. residents to D.C. income tax.

In 2021, the IRS started an enforcement campaign to investigate individuals claiming the benefits of Puerto Rico Act 20, Act 22, Act 60 and presumably other Puerto Rico incentives acts.

The American Taxpayer Relief Act of 2012, Congress's partial solution to avert the "fiscal cliff", was signed into law by President Obama on January 2, 2013.

Jonathan Black authored the article "D.C. Circuit's First Farhy Opinion Requires Reconsideration" published in Tax Notes on May 21, 2024.

The new rules generally do not apply to obligations in place before October 5, 2016 unless they are modified.

The regulatory framework surrounding cryptocurrencies continues to take shape. Earlier this week, Treasury and the IRS issued Announcement 2024-4...

Switzerland will now more liberally permit disclosure of bank account information to the U.S. government without advance notice to the account owner.