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The Second Circuit Court of Appeals has ruled in Soroban Capital Partners v. Commissioner, No. 25-2250 (2nd Cir. 2026), that several partners did not qualify for the limited partner exception from self-employment tax because they “exerted managerial control” over the partnership. Read more
The House passed four tax administration bills with overwhelming bipartisan support on September 15, but the outlook for their enactment depends on the House and Senate resolving differences in their legislative approaches.
House Ways and Means Committee member Ron Estes, R-Kan., has introduced legislation (H.R. 10431) that would overhaul international tax rules.
Treasury and the IRS issued proposed regulations on September 10, 2026, under sections 904(b)(5) and 250(b)(3) of the Internal Revenue Code to implement significant international tax changes enacted as part of the One Big Beautiful Bill Act (OBBBA). The guidance addresses the allocation and…
On 11 September 2026, the OECD/G20 Inclusive Framework (IF) on BEPS released a package intended to support consistent implementation and administration of the Pillar Two global minimum tax rules. The package includes a framework for full legislative peer reviews, an updated GloBE Information Return…
Treasury and the IRS have published proposed regulations under sections 951 and 951A of the Internal Revenue Code addressing how a U.S. shareholder determines its pro rata share of a controlled foreign corporation’s (CFC’s) subpart F income, tested income, or tested loss following changes enacted by…
Enterprise resource planning (ERP) implementations have become a critical component of organizational transformation as organizations navigate acquisitions, mergers, and growth-driven change. While replacing or upgrading core systems can streamline operations, improve data quality, and enhance…
Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (RIN 1506-AB67) on August 11, 2026 permanently removing the requirement for U.S. companies to report information on their beneficial ownership under the Corporate Transparency Act (CTA). The final rule preserves reporting…
On September 2, 2026, President Donald Trump signed the Continuing Resolution (CR) passed by Congress to fund the federal government through December 11, 2026. Although the legislation is primarily intended to prevent a government shutdown, it includes a significant provision for every organization…