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Tax Analysts: Federal and International Tax Developments to Watch in 2026

Mary Katherine Browne et al., Five Tax Cases to Watch in 2026, 190 Tax Notes Fed. 382 (Jan. 12, 2026):

Litigation involving IRS regulation of microcaptive insurance, the validity of a related-party partnership’s basis adjustment claim, and the denial of a medical marijuana dispensary’s business deductions are among the tax cases to watch in 2026.

Mindy Herzfeld (Florida), What’s on the International Tax Agenda for 2026?, 190 Tax Notes Fed. 9 (Jan. 5, 2026):

If the past year’s developments in international tax are any indication, there’s little chance that 2026 will herald a new era of stability in either the United States or the rest of the world. The Trump administration has thrown into turmoil the OECD’s plans for a two-pillar solution for taxation of the digitalized economy, and domestic developments — including in tariffs and on the legislative, regulatory, and judicial fronts — have left taxpayers and their advisers guessing what comes next.

Before considering what might be in store for 2026, let’s take a look back at 2025.


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