The U.S. Tax Court decided Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) in May 2025 leaving financial, tax and legal advisors concerned. The court upended assumptions about the self-employment tax exemption for limited partners in hedge funds, and by analogy to venture capital, and private equity partnerships both in the U.S. and abroad. U.S. citizens and green card holders who are limited partners in hedge funds or similar businesses, including those in foreign countries, should understand the effects of this decision. The case signals a shift away from a state or local law definition of a “limited partner”…

Republicans on the Senate Finance Committee have unveiled their version of the “One Big Beautiful Bill Act” which tackle President Donald Trump’s domestic agenda. While there are some significant differences between the Senate version and the version passed by the House earlier this year, both packages address unpopular reporting requirements: Forms 1099. The House and Senate versions of the bill would both increase the reporting threshold for Forms 1099-K and 1099-NEC, which means that fewer taxpayers would receive those forms at tax time. Background For years, taxpayers who provided certain goods or services worth more than $600 were required to…

Many people think of tax professionals as tax preparers, but tax professionals wear a lot of different hats—sometimes all at once. That’s how you might describe Arielle Tucker, who is both a cross-border Certified Financial Planner™ and Enrolled Agent, who helps U.S. expats build wealth while navigating the tax and financial complexities of life abroad. Arielle lives just outside Zurich, Switzerland, with her husband and two children. That’s fitting as she has spent most of her career in Europe, with time in Berlin, Munich, and Zurich. When she’s not guiding clients through cross-border planning, you’ll find her exploring European cities,…

Four Pennsylvania men have been charged in a scheme to steal tens of millions of dollars in government checks. Tauheed Tucker, Cory Scott, and Alexander Telewoda were arrested and charged with conspiracy to steal government funds, theft of government funds, and mail theft. A fourth defendant, Saahir Irby, was charged with these offenses in addition to a previously charged count of mail theft involving another batch of Treasury checks that he allegedly stole and sold in August 2024. The superseding indictment (a new indictment that replaces a previous one in a criminal case) alleges that, between June 2023 and September…

In this episode of Tax Notes Talk, Jessica Millett of Hogan Lovells discusses the proposed changes to the Opportunity Zone program under the House version of the One Big Beautiful Bill Act and how the Senate might react. Tax Notes Talk is a podcast produced by Tax Notes. This transcript has been edited for clarity. David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes Today International. This week: open to new opportunities. We’ve been covering the House’s One Big Beautiful Bill Act and its changes to tax administration. This week, we’re continuing our…

The House of Representatives unveiled and passed the One Big Beautiful Bill Act, and now the bill is with the Senate. One of the key provisions from the House’s version is a $40,000 cap on state and local income taxes (SALT) paid by individual taxpayers, which, as Forbes reported, was a last-minute alteration to secure the votes for passage in the House. While beneficial for many taxpayers, CNBC reports that the Senate Finance Committee has provided preliminary versions of some items in their version of the bill, including one that would keep the SALT deduction at $10,000. This article describes…

As Congressional Republicans wrangle over the details in President Trump’s “big, beautiful bill,” some commentary suggests there are significant divisions among Republicans. But Trump and virtually all Congressional Republicans strongly support the bill’s central elements–very large tax cuts for the wealthiest Americans, paid for by deep cuts in essential programs while adding trillions to the deficit. Republicans are almost unanimously in favor of the deep, regressive tax cuts in the OBBBA, the “One Big Beautiful Bill Act” (yes, that’s the official name of the legislation). Discussing a May meeting he held with House Republicans, Trump said “we have unbelievable unity.”…

Nestled in the One Big Beautiful Bill Act (OBBBA) winding its way through the U.S. Congress is a tax provision that could have ripple effects around the world: an excise tax on international remittances sent by individuals who live in the United States but are not U.S. citizens or nationals. The United States is by far the largest source of international remittances to lower-income countries. In 2022 U.S. remittances exceeded $79 billion. Compare that with the second largest remitter — Saudi Arabia — which sent a much smaller $39.3 billion. Rounding out the top four countries are Switzerland and Germany,…

Tax Court Judge Goeke’s opinion in Beaverdam Creek Holdings LLC pairs nicely with Judge Lauber’s opinion in Ranch Springs LLC, which I recently covered. Both involve syndicated conservation easements on mining property in the South (Georgia and Alabama respectively) and extensive discussion of the discounted cash flow method of valuation. Another thing they have in common is the law firm representing the petitioner – Jones Day – and an innovative approach to valuation that they have developed and once again failed to sell a Tax Court judge on. Charles E. Hodges II of Jones Day has written me that both…

The traditional individual tax filing season ended two months ago (those of us on extension still have a few months to go), but the IRS is still in the news. Most notably, the Senate has confirmed Billy Long as the new commissioner of the IRS (you can read more about that in a bit as part of our Deeper Dive below). How Long’s tenure might impact the future of the IRS and tax administration is still a question, but far from the only one. Still to be determined? What the tax picture might look like during the next filing season…