Wrapping Up November – And Looking Forward To December

President Trump's Executive Order 14435 directs the IRS to provide temporary relief from federal tax penalties on dyed diesel fuel used for highway purposes. The relief, retroactive to October 1, 2026, suspends enforcement and recordkeeping requirements while the Treasury Department explores options to eliminate deferred tax obligations entirely.

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.

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

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'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.

Partner Scott H. Novak specializes in tax law, focusing on tax controversy, trusts and estates, planning, and transactional tax matters. His extensive experience encompasses federal, state, foreign, and employment tax issues, handling everything from non-filing cases to complex audits, estate planning, and settlements with tax authorities.

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.

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.

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...