News & Insights

News, developments, and publications from our team of renowned tax lawyers.

Recent Highlights

  • June 3, 2026

How the IRS is Sharpening its Focus on “Microcaptive” Insurance Arrangements

Attorneys Ellen Brody and Jacob Entin write about how the IRS is sharpening its focus on “microcaptive” insurance arrangements, and four recent cases demonstrate how the agency is attacking 831(b) structures. Read more in their latest Tax Stringer article.
  • May 27, 2026

Ellen Brody Secures Summary‑Judgment Win in Karp v. United States

Partner Ellen Brody secured a victory in the United States Court of Federal Claims, which granted a summary judgment in a tax refund case.
  • April 22, 2026
  • Publications

Treasury Issues Proposed Regulations on the Taxation of Foreign Governments

Ezra Dyckman and Charles Nelson explain how the new proposed regulations provide important guidance on the U.S. income tax consequences of those investments.
  • April 17, 2026
  • Publications

Consequences of Corporate Status Suspension

In their latest article for the New York Law Journal, Elliot Pisem and David E. Kahen explain, "Consequences of Corporate Status Suspension: Arbor Vita Corp. v. Commissioner."
  • 04/07/2026
  • News

Ezra Dyckman on REIT Joint Venture Compliance Complexities

Roberts & Holland LLP partner Ezra Dyckman breaks down several often‑overlooked tax risks in REIT joint ventures and OP transactions.
  • 03/20/2026
  • News

Ezra Dyckman speaking at Nareit REITwise Education Conference

Roberts & Holland's Ezra Dyckman is presenting on Partnership Tax at the Nareit REITwise 2026 Educational Conference.
  • February24, 2026
  • Publications

New Law Limits Investment Interest Expense Deductions

Ezra Dyckman and Charles Nelson explain how a new federal tax law limits deductions for investment interest expenses.
  • February 19, 2026
  • Publications

Taxpayer’s Attempted Characterization of Stock as Debt Rejected: Aventis, Inc. v. Commissioner

Elliot Pisem and David E. Kahen provide an analysis of Aventis v. Commissioner: why the FASIT failed statutory and grandfather rules, and how the court applied substantial compliance and debt vs. equity tests.
  • February 2, 2026
  • Publications

Help Is Available If You Forgot to Make a QEF Election

Ellen Brody and Avi Leiner published a new analysis in the latest issue of  The New York State Society of CPAs’s TaxStringer on Rev. Proc. 2026‑10, the IRS's latest guidance on retroactive Qualified Elected Fund elections for Passive Foreign Investment Companies.  
  • December 23, 2025
  • Publications

Holiday Bonus: OBBBA Expands Bonus Depreciation Rules

Ezra Dyckman and Charles Nelson explain how the new federal tax law expands bonus depreciation opportunities but caution that the rules can be complicated and may not help all taxpayers as much as expected.
  • December 5, 2025
  • Publications

Why Reading IRS Notices Matter

In her December 2025 TaxStringer article for the New York State Society of CPAs, Ellen Brody highlights a U.S. Tax Court case that serves as a cautionary tale for taxpayers who fall behind on filings or ignore IRS correspondence.
  • December 3, 2025
  • News

Additional Restrictions on Charitable Deductions Take Effect in 2026

As we approach the end of 2025, taxpayers should keep in mind that, due to recent changes in law, deductions for charitable contributions made in 2026 will generally be less valuable than deductions for charitable contributions made in 2025.

  • October 23, 2025
  • Publications

Substance over Form and Sham Arguments Rebuffed: ‘Perrigo Co. v. United States’

In an article for the New York Law Journal, Elliot Pisem and David E. Kahen discuss a recent District Court decision regarding the application of substance over form and other “tax common law” doctrines in a context in which the Internal Revenue Service also proposed adjustments under IRC section 482.
  • October 22, 2025
  • Publications

Disallowance of Excess Business Losses Made Permanent

In their latest article for the New York Law Journal, Ezra Dyckman and Charles S. Nelson write about how one often-overlooked provision that was made permanent by the OBBBA could have a significant negative impact on certain taxpayers, particularly those in the rental real estate industry.
  • October 1, 2025
  • Events

Michael Miller to Speak at the 84th Institute on Federal Taxation

Michael J. Miller is speaking at the NYU School of Professional Studies 84th Institute on Federal Taxation, which takes place from October 19-24 in New York City. His session, “Planning for Foreign Investment in U.S. Real Estate in the Post-OBBB Era,” includes a special focus on planning for investment in U.S. real estate by foreigners following the enactment of the OBBB.
  • October 13, 2025
  • Publications

International Tax Journal Article: How Many FBARs Are Enough?

In his latest article for Wolters Kluwer International Tax Journal, Michael J. Miller writes that more than one U.S. person may be obligated to report the same foreign financial account. This article is reprinted with the publisher's permission from the International Tax Journal a bi-monthly journal published by WOLTERS KLUWER.  Copying or distribution without the publisher's permission is prohibited. To subscribe to the International Tax Journal or other WOLTERS KLUWER Journals please call 800-449-8114 or visit www.cchcpelink.com.
  • September 10, 2025
  • Events

Aaron Gaynor to Speak at the 2025 Federation of Exchange Accommodators Annual Conference

Roberts & Holland's Aaron S. Gaynor is speaking at the 2025 Federation of Exchange Accommodators Annual Conference which takes place September 15-17 in Atlanta, Georgia.
  • September 5, 2025
  • Publications

Recent Court Cases That Tax Professionals Should Know

Read Ellen Brody's September column, IN CASE YOU MISSED IT, for the NYCPA - The New York State Society of CPAs publication, Tax Stringer.
  • September 2, 2025
  • Publications

The OBBBA Makes QOZ Program (But Not Deferral) Permanent

The One Big Beautiful Bill Act (OBBBA) extended the popular Qualified Opportunity Zones (QOZ) program with some tweaks, but the changes do not allow current QOZ investors to permanently defer gains already invested in the program.

  • 08/21/2025
  • Publications

“Break Fee” Classified as Ordinary Deduction: AbbVie, Inc. v. Commissioner

A "break fee" paid in connection with the termination of a plan to combine two companies under a holding company structure was determined by the Tax Court to be allowable as an ordinary deduction.
  • 07/15/2025
  • News

Aaron Gaynor to Speak at NYU Like-Kind Exchange Conference

Roberts & Holland's Aaron Gaynor will participate in the Partnership Transactions and Ethics panels at the NYU Like-Kind Exchange Conference from July 24-25, 2025 at the Westin New York at Times Square.
  • 07/10/2025
  • Publications

Loss Deduction Denied Under Public Policy Doctrine: Hampton v. Commissioner

A recent memorandum decision of the Tax Court confirms that a loss otherwise deductible under Section 165 of the Internal Revenue Code may nonetheless be disallowed under the "public policy" doctrine.
  • 07/10/2025
  • News

Michael Miller Co-Chairs Conferences at NYU’s Summer Institute in Taxation

Roberts & Holland's Michael J. Miller will co-chair the Introduction to International Taxation Conference, on Monday, July 14, through Wednesday, July 16, and the Advanced International Taxation Conference, on Thursday, July 17, through Friday, July 18, both of which are part of NYU's Summer Institute in Taxation.
  • 07/09/2025
  • Publications

OBBBA and Qualified Opportunity Zones (QOZs): The Top Five Things That You Need to Know

The “One Big Beautiful Bill Act” has made QOZs permanent, tweaked the rules, and imposed new reporting requirements.