Lotus Li

Changing a business’s federal tax classification or legal form can trigger deemed transactions for income tax, employment tax, and information reporting.

The federal basic exclusion amount for estate and gift tax is increased to $15,000,000 per person (indexed for inflation) beginning for decedents dying and gifts made after December 31, 2025.

U.S. citizens and resident aliens are taxed on worldwide income, even if they live and work abroad. Report all foreign-source earned and unearned income on a U.S. return each year. Nonresident aliens generally owe U.S.

States generally tax wage income where the work is performed; the resident state typically taxes all income but offers a credit for taxes paid to other states to mitigate double taxation. Convenience-of-the-employer rules and reciprocity agreements can change the result.

TET lets partnerships and S corporations pay state income tax at the entity level so owners can receive a federal deduction not limited by the individual SALT cap. Nearly all high-tax states, and many others, now offer PTET.

The IRS treats cryptocurrency and other blockchain-based tokens as “digital assets,” and digital assets are treated as property. General property tax rules apply to purchases, sales, exchanges, and dispositions.