Tax Talks, published by Proskauer Rose LLP, focuses on developments and analysis in tax law and policy. The blog covers topics such as the economic substance doctrine, like-kind exchanges under Section 1031, domicile and residency issues for tax purposes, and regulatory changes affecting real estate investment trusts (REITs). It addresses judicial decisions, IRS guidance, and proposed regulations impacting tax compliance, planning, and litigation. The content is relevant to practitioners and clients navigating complex federal and state tax rules, including corporate, partnership, and individual tax matters.
Introduction
On September 4, 2026, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) published proposed regulations (the “Proposed Regulations”) that would revoke the tax-exempt status of a private school if it adopts, maintains, or…
Introduction
On August 14, 2026, the Maryland Tax Court struck down the state’s Digital Advertising Gross Revenues Tax (the “Tax”). In Apple Inc. v. Comptroller, Google LLC v. Comptroller and Peacock TV, LLC v. Comptroller, the court held that the…
On August 12, 2026, in K Alain, L.L.L.P. v. Commissioner,[1] the U.S. Court of Appeals for the Fifth Circuit withdrew its taxpayer-friendly January 16, 2026 opinion in Sirius Solutions, L.L.L.P. v. Commissioner,[2] and replaced it with a…
On 13 July 2026, HMRC published a consultation on simplifying the process for obtaining treaty relief from UK withholding tax on interest paid overseas.
The consultation considers whether UK payers should be able to apply treaty relief at source without…
The UK government has published draft legislation for a new Securities Transfer Tax (STT), which is expected to replace the existing stamp duty and stamp duty reserve tax (SDRT) regimes for transfers of securities.
The proposal is intended to modernise…
HMRC has published a consultation on proposals to modernise the UK tax framework for distributions and repayments of capital made by companies to individual and trust shareholders. A key feature of the consultation is a proposal to align the income…
The Supreme Court has handed down its judgment in HMRC v BlueCrest Capital Management (UK) LLP, dismissing BlueCrest’s appeal and providing important clarification on the application of the salaried members rules to investment management LLPs.
The decision is particularly significant…
HMRC has published updated guidance on the revised share reorganisation anti-avoidance rules following the changes introduced by Finance Act 2026. The guidance provides welcome confirmation that standard private equity management rollover arrangements should continue to benefit from share-for-share exchange relief…
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…
On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $2.4 billion deduction and imposed a 40% penalty with respect…
