Pillar Two And The “Side-By-Side” Agreement: A Guide For The Perplexed*

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.

Section 529 plans provide a tax-advantaged way to save for education expenses, but account holders should be mindful of important differences...

Over its 87-year history, enforcement of the Foreign Agents Registration Act has ebbed and flowed. Here is a snapshot of recent and current developments in FARA enforcement.

A U.S. House Committee on Ways & Means hearing on “Foreign Influence in American Nonprofits” last month and recent letters by Republican state Attorneys General accusing specific organizations of violating FARA have resulted in some additional public attention about how FARA relates to the nonprofit/tax-exempt sector.

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.

On May 1, 2026 a federal jury in Miami found former Florida Congressman David Rivera guilty after a five-week trial of conspiracy to violate FARA, failure to register under FARA, and other crimes. Esther Nuhfer, one of Rivera’s associates, was convicted of the same FARA offenses.

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...

The FARA Conference convened last Thursday, September 24th, in Washington, D.C., bringing together legal practitioners, scholars, and others who encounter the Foreign Agents Registration Act for a full day devoted to the statute.

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...

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

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.

The Securities and Exchange Commission has proposed rescinding Rule 206(4)-5, the pay-to-play rule that has restricted political contributions by investment advisers since 2010. The proposal would eliminate automatic two-year compensation bans triggered by contributions exceeding $150 and shift responsibility for policing pay-to-play risk to individual adviser compliance programs.