5+ day, 19+ hour ago  (325+ words) On May 5, 2026, the Internal Revenue Service (IRS) released Revenue Procedure 2026-21 (the Rev. Proc.), which reinstates a program under which taxpayers may request private letter rulings (PLRs) on significant issues arising in certain corporate transactions[1] without asking the IRS to rule…...

5+ day, 16+ hour ago  (380+ words) Non-U. S. individuals who own U. S. assets, including real estate, stocks, or business interests, may face significant U. S. estate tax exposure, often without realizing it. As cross-border investment between the United States and the rest of the world continues to grow, many foreign…...

1+ week, 6+ day ago  (82+ words) IRS Rev. Proc. 2026-21, 2026-22 IRB 1, issued May 5, 2026, reinstates the Internal Revenue Service's "significant issue" letter ruling program, under which the IRS will rule on specific, significant issues posed by a transaction without ruling on the entire integrated transaction. .. .By: Fenwick & West…...

1+ mon, 1+ day ago  (641+ words) Administering an estate that owns a business presents unique challenges for executors in both New Jersey and Pennsylvania, where the obligations of estate administration intersect with the operational and financial demands of an ongoing enterprise. .. .By: Stark & Stark Administering an…...

1+ week, 4+ day ago  (508+ words) On December 22, the Internal Revenue Service (IRS) announced proposed updates to its Criminal Investigation Voluntary Disclosure Practice (VDP), opening a 90-day public comment period that closed on March 22. Revised procedures are expected to take effect six months after the changes…...

1+ week, 5+ day ago  (114+ words) Procedural History " the District Court Opinion The Tenth Circuit framed the question for decision narrowly as whether the economic substance doctrine was relevant to Project Soy, and if so, did Project Soy meet the requirements of the economic substance doctrine…...

2+ mon, 15+ hour ago  (241+ words) The IRS' Criminal Investigation Voluntary Disclosure Practice (VDP) has long served as the principal pathway for taxpayers with potential criminal tax exposure to self-correct their past noncompliance and pay outstanding tax liabilities with interest and penalties and, in return, receive…...

2+ mon, 5+ day ago  (170+ words) Welcome to the latest edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. We pull together the items we deem most important to provide updates you need…...

2+ mon, 2+ week ago  (268+ words) Welcome to this week's edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to provide updates…...

2+ mon, 3+ week ago  (184+ words) The February 19, 2026, decision of the United States Tax Court, which rejected the valuation of the charitable contribution of a conservation easement, is most informative because it turned on the highest and best use (HBU) of the property. Without getting into…...