The Section 382 Consolidated Return Regulations

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.

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.

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.

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).

The Federal Communications Commission has adopted sweeping new restrictions targeting equipment containing components from entities on its Covered List, fundamentally reshaping how manufacturers, online marketplaces, and equipment modifiers must approach FCC compliance. These rules establish unprecedented prohibitions on logic-bearing hardware components, impose strict display requirements for e-commerce platforms, and clarify when existing authorizations can support equipment modifications.

The Trump administration's Venezuela oil deal and expanded General Licenses have opened unprecedented opportunities for multinationals to invest in Venezuela's energy, mining, and telecommunications sectors, while simultaneously launching "Operation Economic Outcast" to impose crushing economic pressure on Iran.

The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.

The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 has become law, imposing sweeping sanctions on Russian officials, financial institutions, and shadow fleet vessels while authorizing tariffs up to 100 percent on major purchasers of Russian oil and natural gas. How will these new measures impact global trade relationships, particularly with China and India as the largest buyers of Russian crude?

Israel's upcoming elections represent a critical juncture as voters weigh Prime Minister Netanyahu's wartime leadership against mounting domestic crises including ultra-Orthodox draft exemptions...

Global sanctions enforcement intensifies as the US expands its economic pressure campaigns against Cuba, Iran, and Venezuela while the UK and EU strengthen their Russia sanctions frameworks. Meanwhile, China pushes back against US sanctions targeting its companies over alleged Iran ties, and a Dutch chipmaker faces asset freezes amid a complex ownership dispute involving Chinese courts.

President Trump's Executive Order 14421 declares a national emergency to secure the U.S. bulk-power system, imposing new restrictions on foreign-produced electric equipment that poses national security risks. The order prohibits certain imports and installations while directing the Department of Energy to identify and potentially replace existing vulnerable equipment already on the grid.

Western countries are increasingly using sanctions waivers as diplomatic bargaining chips to secure prisoner releases and achieve transactional geopolitical goals. Recent US-Belarus and France-Azerbaijan deals highlight this trend, raising questions about sanctions policy coherence, alliance coordination, and the long-term effectiveness of economic restrictions as foreign policy tools.

Brazil is embroiled in its most significant fraud investigation since the 2014 Lava Jato probe, following the largest bank fraud in the country’s history.

The US and China have extended their trade truce by two months, delaying potential tariffs while sanctions targeting Iranian aviation and Chinese entities continue. Multiple countries have banned Iranian airlines following US measures, and the EU has renewed its Russia sanctions regime for three years while removing two prominent Russian businessmen from its list.