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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 Tax violated the federal Internet Taxation Freedom Act…

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 first obtaining a formal direction from HMRC. If implemented, this…

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 and simplify the UK’s stamp taxes on shares regime by…

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 for asset managers, hedge fund managers and other investment…

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 on the entire integrated transaction.[2]…

The Court of Appeal has confirmed in HMRC v M R Currell Ltd that, prior to the introduction of the disguised remuneration rules, a genuine and repayable loan made via an employee benefit trust (EBT) is not taxable as employment income.

Although the decision relates to a pre-Part 7A regime…

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Update: The National Taxpayer Advocate has published a blog post urging taxpayers to evaluate whether they have claims for refund based on the recent Abdo and Kwong decisions. Importantly, the Taxpayer Advocate suggests that the argument for penalty and interest relief based on the COVID pandemic disaster declarations is…

On March 19, 2026, in Jones Bluff, LLC v. Commissioner, 166 T.C. No. 6 (2026), the Tax Court held that a partnership could not assert due process claims to invalidate an IRS adjustment on behalf of its partners under the Bipartisan Budget Act of 2015 (the “BBA”) regime. The…

Although many of the procedural rules for auditing partnerships at the federal level have changed under the Bipartisan Budget Act of 2015 (the “BBA”), some principles—like the effect of actual notice—remain the same. Under the BBA, the IRS proposes partnership-level adjustments in a Notice of Proposed Partnership Adjustment (“NOPPA”) and later finalizes them in a Notice of Final Partnership Adjustment (“FPA”). If the IRS issues the FPA after the statute of limitations expires, the partnership can seek to invalidate it as untimely.

A reviewed Tax Court opinion filed March 9, 2026—Mammoth Cave Property, LLC v. Commissioner, No. 5401-24, 166 T.C. No. 4—shows the limits of “defective notice” arguments when the partnership actually received the NOPPA and participated in the process.