Section 892 Proposed Regulations – Applicability Date ReliefREG-00349656-26 (Scheduled for Publication June 1, 2026)May 29, 2026Executive SummaryNew Transition Period, Grandfathering of Certain Previously Effectuated and Binding Commitment…

Three Leadership PerspectivesTax in the traditional insurance industry is at an inflection point. While many tax functions remain heavily focused on compliance, a combination of increasing complexity, workforce constraints, and rapid advances in…

On May 5, 2026, the IRS issued Rev. Proc. 2026-21, reviving a practice that allows taxpayers to request private letter rulings (PLRs) on discrete, significant tax issues arising in complex corporate transactions, without requiring a ruling on the…

On March 18, 2026, the IRS issued Revenue Procedure 2026-17 (the Procedure), which permits taxpayers to revoke certain previously “irrevocable” elections under the §163(j) business interest deduction limitation regime. Most notably, the relief…

Tokenization can represent ownership or economic rights in a real-world asset (RWA), such as real estate, debt, fund interests, artwork, receivables, bank deposits, etc. as a digital token on a public blockchain. The result can be fractional…

The application period for the 2025 Massachusetts Life Sciences Tax Incentive Program (LSTIP) opened in mid-January and will close at 2 p.m. on March 31, 2026. This program is offered through the Massachusetts Life Sciences Center (the MLSC, the…

On February 20, 2026, Treasury and the IRS released Notice 2026-16, providing interim guidance on the new 100% special depreciation allowance for qualified production property (QPP) under Internal Revenue Code §168(n).[1]  Enacted as part of…

As 2025 financial reporting deadlines approach, companies are assessing the income tax accounting implications of the One Big Beautiful Bill Act (OBBBA), enacted on July 4, 2025. For organizations with M&A activity, OBBBA’s retroactive…

New Hampshire is currently offering a generous tax amnesty program. The program commenced on December 1, 2025, and it will end on February 15, 2026.These types of programs are not offered very often, so it is wise to consider taking advantage…

Treasury and the IRS recently issued four notices announcing proposed regulations that would implement key changes to the international tax provisions of the Internal Revenue Code, as enacted by the One Big Beautiful Bill Act (OBBBA).[1] The…

The One Big Beautiful Bill Act (OBBBA)  introduced several long-anticipated legislative changes, including the so called “Big 3”: (1) restoring the deductibility of domestic research and experimental expenditures (§174A), (2) extending 100%…

The One Big Beautiful Bill Act (OBBBA), signed on July 4, 2025, modernizes Internal Revenue Code Section 1202 (Qualified Small Business Stock, or QSBS) and makes its tax benefits more accessible and more valuable to eligible noncorporate taxpayers.…

On November 21, 2025, Treasury and the IRS released final regulations (the Final Regulations) governing the 1% excise tax on corporate stock repurchases enacted by the Inflation Reduction Act of 2022. These final rules mark a significant shift from…

On May 20, 2025, Maryland Governor Wes Moore signed the Budget Reconciliation and Financing Act (BRFA) of 2025, closing a $3.3 billion budget gap while significantly expanding the state’s sales and use tax base. Among its most impactful provisions…

In Mexico, a company with a local presence that is currently undergoing, or may in the future undergo, a tax review for FY 2020 of its transfer pricing policies (or other international tax matters) that may give rise to a case that could be resolved…

In the context of mergers and acquisitions (M&A), Tax is often under the spotlight during the period leading up to a deal signing. During this time, due diligence is conducted, a step plan is developed outlining steps required to complete the…