Tax Law Updates

  IRS Rejects Comfort Rulings Without a Genuine Legal Need Businesses often seek IRS guidance before completing complex transactions. However, under the IRS’s 2026 ruling procedures, requests that simply ask the IRS to confirm an obvious tax result—commonly called “comfort rulings”—are generally discouraged. Instead, the IRS expects ruling requests to involve a genuine legal question...

  IRS Limits Advance Rulings on U.S. Trade or Business Status For foreign individuals and businesses, one of the most important U.S. tax questions is whether their activities create a U.S. trade or business (USTB). The answer can determine whether income is subject to U.S. taxation, reporting requirements, and withholding obligations. However, obtaining an advance...

    IRS Clarifies Portfolio Interest Rules for Foreign Investors The portfolio interest exemption can allow certain foreign investors to receive U.S.-source interest without the standard 30% withholding tax. However, qualifying for this exemption requires careful analysis, and recent IRS guidance reinforces that these determinations are based on detailed ownership rules rather than broad assumptions....

  IRS Rejects Frivolous Tax Arguments—and They Can Be Costly Not every tax position deserves IRS consideration. The IRS continues to take a firm stance against frivolous tax arguments and may impose significant penalties on taxpayers who raise them in tax returns or certain IRS submissions. Before relying on an unconventional tax strategy, it’s important...

    IRS Treats Permanent Establishment Determinations as Highly Fact-Specific For foreign businesses operating in the United States, one of the most important tax questions is whether their activities create a Permanent Establishment (PE) under an applicable income tax treaty. The answer determines whether the United States can generally tax the business’s profits. While the...

  IRS Competent Authority Cases: Why Other IRS Actions May Pause When a taxpayer seeks relief under a U.S. tax treaty through the IRS Competent Authority process, the handling of the case changes significantly. Rather than multiple IRS divisions addressing the same issue, the Competent Authority generally takes the lead on resolving treaty-related matters.  ...

  How Capital Gains Tax Works in 2026 Whether you’re selling stocks, investment property, or other investments, understanding how capital gains are taxed can help you make smarter financial decisions and potentially reduce your tax bill. For the 2026 tax year, federal capital gains tax depends on three primary factors: Whether the property is a...

  IRS Tightens Foreign Tax Credit Rules for 2026 Claiming a Foreign Tax Credit (FTC) can help prevent double taxation, but qualifying for the credit has become increasingly complex. Recent IRS guidance emphasizes that not every foreign tax paid is automatically creditable. For many taxpayers with international investments or foreign business operations, careful analysis is...

  Capital Gains Tax Rates for 2026   If you sell stocks, mutual funds, ETFs, real estate investments, or other capital assets in 2026, understanding how capital gains are taxed can help you avoid surprises and make smarter tax-planning decisions. One of the biggest advantages of long-term investing is that long-term capital gains are generally...

  Where Is My Refund? 2026 IRS Tracking Guide   Waiting for your tax refund can be frustrating, especially when you’re unsure whether your return has been processed or when your money will arrive. Fortunately, the IRS provides several tools that allow taxpayers to track their federal refunds throughout the process. For 2026, refund status...