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New CFC Rules for 2026: Section 958(b)(4) Restoration and the Foreign Controlled Corporation Provisions
The One Big Beautiful Bill Act: Tax Provisions
Proposed CAMT Guidance May Have Significant Impact on Asset Management

Coast-to-Coast Tax Residency: Comparing New York and California Residency Rules
Beneficial Owner Disclosure Under the New York LLC Transparency Act

Latest Articles

  • Interim Guidance Simplifies Application of the Corporate Alternative Minimum Tax to Partnerships

    By:
    Aaron Lebovics, CPA, Annet Thomas-Pett, CPA, Charwin Embuscado, CPA, Jason Black, CPA, Michael Hauswirth, JD, Craig Gerson, JD, LLM, Corey Dalton, CPA, and Brett York, JD
    |
    Sep 4, 2025
    On Jul. 29, 2025, Treasury and the IRS issued Notice 2025-28 (the Notice) indicating their intent to partially withdraw proposed Corporate Alternative Minimum Tax (CAMT) regulations related to partnerships. The Notice also provides interim guidance to simplify CAMT’s application to partnerships. Forthcoming proposed regulations will include rules similar to the interim guidance provided in the Notice. 

  • Impact of SECURE Final Regs on Planning for Trusts

    By:
    Steven B. Gorin, CPA, Esq., CGMA
    |
    Sep 4, 2025
    This article discusses selected issues under the 2024 final regulations implementing the SECURE Act and SECURE 2.0.

  • Court Decision Might Mean Foreign Tax Credits Can Offset U.S. Tax— but Don’t Jump at the Chance

    By:
    Alicea Castellanos, CPA
    |
    Sep 4, 2025
    The U.S. is one of the only nations that imposes income tax on its citizens who live abroad. The theory is that this taxation guarantees Americans worldwide pay their share for the privilege of U.S. citizenship and, perhaps more importantly, prevents them from hiding income by living overseas. 

  • First Look at the Tax Provisions of “The One Big Beautiful Bill Act”: How It Affects Individuals

    By:
    Mark H. Levin, CPA, MS (Taxation)
    |
    Aug 1, 2025

    On Jul. 4, 2025, President Trump signed The One Big Beautiful Bill Act (OBBBA) into law as Public Law 119-21. Title XI of the law contains the tax provisions for the 2025–2026 federal budget.

  • New CFC Rules for 2026: Section 958(b)(4) Restoration and the Foreign Controlled Corporation Provisions

    By:
    Philip D.W. Hodgen
    |
    Aug 1, 2025

    The One Big Beautiful Bill Act, signed on Jul. 4, 2025, includes changes that apply to controlled foreign corporations and their US shareholders. Two of those changes affect whether a US taxpayer has a Form 5471 filing requirement and an income inclusion for a foreign corporation’s subpart F income or net Controlled Foreign Corporations (CFC) tested income—the new name for global intangible low-taxed income. The changes are effective for foreign corporation tax years beginning after Dec. 31, 2025. 

  • Proposed CAMT Guidance May Have Significant Impact on Asset Management and Real Estate Reporting Part 2

    By:
    Aaron Lebovics, Annet Thomas-Pett, CPA, Charwin Embuscado, CPA, Jason Black, CPA, Jennifer Wyatt, CPA, and Michael Hauswirth, JD
    |
    Aug 1, 2025
    The proposed regulations contain rules addressing "adjustments to apply certain subchapter K principles" in connection with contributions to and distributions from partnerships. In general, these rules require the Corporate Alternative Minimum Tax Regs (CAMT) entity, any other partner in the relevant partnership, and the partnership itself to include in their AFSI any income, expense, gain, or loss reflected in the financial statement income (FSI) as a result of the contribution to or distribution from the partnership.

  • Coast-to-Coast Tax Residency: Comparing New York and California Residency Rules

    By:
    Daniel P. Kelly & Joseph F. Tantillo, Esq.
    |
    Aug 1, 2025
    A few years ago, one of the authors examined the trials and tribulations taxpayers face when navigating east-and-west-coast residency issues.[1] Over the last seven years, the world and individual tax residency considerations have undergone material change. Taxpayers still pursue changes in tax residency for all the classic reasons—retirement, a new job, health circumstances, or different weather—but there are several more recent residency motivators in play. 

  • Beneficial Owner Disclosure Under the New York LLC Transparency Act

    By:
    George Martin, Kevin Matz, CPA, JD, LLM, and Tracy McLaughlin, CFP
    |
    Jun 1, 2025
    After a rollercoaster of activity related to the federal Corporate Transparency Act (CTA), the U.S. Treasury Department (Treasury) announced Mar. 2, 2025, that it will not enforce any penalties or fines associated with beneficial ownership information reporting for U.S. reporting companies. (“Treasury Department Announces Suspension of Enforcement of Corporate Transparency Act Against U.S. Citizens and Domestic Reporting Companies,” https://tinyurl.com/5bvp4mt7). 

  • Has the No Lookback for Home Care Medicaid in New York Run Its Course?

    By:
    Anthony J. Enea, Esq.
    |
    Jun 1, 2025
    When the state of New York passed legislation in 2020 creating a 30-month lookback period for uncompensated transfers of assets under the Medicaid home care program, few imagined that almost five years later, the law would still not be in effect.

  • Proposed CAMT Guidance May Have Significant Impact on Asset Management and Real Estate Reporting Part 1

    By:
    Aaron Lebovics, Annet Thomas-Pett, CPA, Charwin Embuscado, CPA, Jason Black, CPA, Jennifer Wyatt, CPA, and Michael Hauswirth, JD
    |
    Jun 1, 2025

    Proposed guidance related to the corporate alternative minimum tax (CAMT) may create incremental reporting burdens for asset management and real estate funds.

    On Sept. 12, 2024, the Treasury Department and the IRS issued proposed regulations implementing the CAMT. Enacted in 2022 as part of the Inflation Reduction Act, the CAMT imposes a 15 percent minimum tax on the adjusted financial statement income (AFSI) of an “applicable corporation.” The CAMT is effective for tax years beginning after Dec. 31, 2022.
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Tax Jokes
  

What does an accountant say when getting on a train? Mind the GAAP.
 
https://parade.com/1317763/jessicasager/accounting-jokes/

One Big Beautiful Bill Act: Tax Deductions for Woking Americans and Seniors, Internal Revenue Service

IRS Staff Cuts Could Put Burden on Practitioners to Explain OBBBA, Association of International Certified Professional Accountants

Long's IRS Era: Implementing the 'Big Beautiful Bill' and Agency's Culture Shift, The Trusted Professional

Expert: OBBBA Does Not End Tax Credits Right Away, The Trusted Professional

Congress Passes Act Allowing Tax Relief When a State Declares Disaster, Association of International Certified Professional Accountants

National Taxpayer Advocate Issues Mid-Year Report to Congress, Internal Revenue Service

TIGTA: IRS Reduces Workforce by 25 Percent, Jeopardizing Upcoming Filing Season,The Trusted Professional

IRS Withdraws Proposed Regulation on Built-In Gains and Losses Under Section 382,The Trusted Professional

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.