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Each one takes a live market event, finds the tax mechanism underneath it, walks the numbers, and ends with a view. Subscribe by email · RSS

Latest alert · October 2026

The Quiet Parts of the UK Budget

Banks and landlords got the headlines. U.S. LLC members, sovereign LPs, and London families got the changes that will last.

The UK Budget of October 28 saved its lasting changes for the back pages. U.S. LLC members in London get a long-awaited credit, but only for tax “paid by them personally,” which may leave out state PTET and New York City UBT. Sovereign investors will pay UK tax on owning property from 2029 but not on lending against it. Tax on interest and rent now runs 25 points above tax on gains, and a new inheritance tax rule on trust debts is already in force.

October 2026

Bee law · Legal history · UK tax · Pollination

The Law of the Hive

The most personal thing we have written, and the second note with nothing to do with your K-1. It began with insomnia in 2020 and the English rules of beekeeping, and it runs from Justinian to a seventh-century Irish tract on bee stings, a Nuremberg beekeepers' guild with its own court and crossbows, the straw hives the English burned every autumn, and a disease that emptied Edwardian apiaries and may never have existed, through to this year's fights over pesticides, honey labels, and a hornet from France. Then, because we could not help ourselves, the tax: HMRC zero-rates the hire of honey bees and standard-rates the box they arrive in.

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October 2026

Artificial intelligence · Research credit · Section 174A · Sales tax

The Meter Is Running

Apollo’s Torsten Slok finds no AI payoff yet outside the tech giants, and companies now call token spending a cost center. The tax code already shares that cost: every token is deductible, and tokens spent building new software can earn a research credit, if usage is tagged when it is consumed. We run the numbers on one $10 million model bill and set out four steps for year-end.

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October 2026

Conservation easements · Valuation · Appraisals · Penalties · Partnerships

Speculative Value, Forty Percent Penalty

In Watson Lake, Del Monte, and Lontrac, the Tax Court adopted the government’s comparable sales, set aside cash flow models built on uses the land had no right to, disallowed $39.4 million outright on one clause in a deed, and left no reasonable cause defense to the 40 percent penalty. The reasoning reaches any discount, GRAT, or gift of property that rests on an appraisal.

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October 2026

IRS guidance · ETFs and exchange funds · Estate planning · Opportunity zones

Two Days, One Bulletin, and a Very Busy Treasury

Notice 2026-62 and a companion ruling treat the classic ETF seeding trade as taxable, with no prospective-only relief. The IRS acquiesced in Siemens, the November 7520 rate rose to 6.2%, the 871(m) phase-in runs through 2028, and crypto trusts, opportunity funds, and consolidated groups each got new rules. Seven items, in order of how much coffee they required.

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October 2026

Private credit · PIK · BDCs

The Quiet Part

Monroe Capital’s Ted Koenig calls PIK toggles and covenant-dodging extensions “silent default.” For the lender, PIK from day one is original issue discount, taxed as it accrues with no cash. On a $100 million loan, a partnership investor pays $16.5 million of tax over three years on interest never received, and a 60-cent settlement turns it into a capital loss.

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October 2026

Commercial real estate · Debt workouts · Partnership tax

Handing Back the Keys

The 10-year Treasury hit its highest level since 2002, buyers are retrading signed deals, and $875 billion of commercial and multifamily mortgages mature this year. We price the three exits (modify the loan, hand back the keys, or bring in rescue capital) partner by partner on one office building. A deed in lieu can hand an investor a $4 million tax bill on a building it no longer owns, and the rescue recap hides a chargeback that one clause in the operating agreement fixes.

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October 2026

California · Wealth tax · Founders and fund principals

The Door Closed in January

On November 3, California votes on Proposition 40, a one-time 5% tax on the worldwide net worth of billionaires who were California residents on January 1, 2026. The residency date has already passed; what is still open is how private stock, carried interest, and trusts get valued, and what to do before December 31.

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October 2026

International tax · Net CFC tested income · Foreign tax credits

Twelve Point Six

For a corporate owner, the number that sets the 2026 bill is 14 percent: the blended foreign rate, measured the U.S. way, at which credits cover the tax. Below it, the low-taxed plant writes the bill. We work one portfolio through the 2026 rules and set out three decisions for 2026 models.

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October 2026

Structured credit · CLOs · PFIC and CFC · Fund structuring

The Return of Capital

A $10 million CLO equity investment pays $1 million of cash, ends the year marked at $9.5 million, and reports $1.4 million of taxable income. All three numbers can be right. Our special report follows the money from the issuer, through the fund, to the investor, and sets out what an approval package should require before the closing, the reset vote, or the exit.

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October 2026

Firm news · Tax policy · Capital gains

Carlos Schmidt Co-Authors Bloomberg Law Op-Ed on Fixing Inflation and Capital Gains

Carlos Schmidt co-authored an op-ed in Bloomberg Law proposing a revenue-neutral, statutory fix to inflation-indexed capital gains, paired with a modest rate increase.

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October 2026

Tax controversy · Estate and succession planning · Separation of powers · Tariffs

Neither Sword Nor Purse

A Michigan county sold a family's $194,400 house at auction for $76,008 to collect $2,241.93 of unpaid property tax. Two years earlier the Court let the IRS add $889,914 of estate tax back onto a brother's life-insurance-funded buy-sell. Neither opinion reads like a tax treatise. Both decide who keeps the money. Our special report reads 2,890 of the Court's tax decisions, from 125 stipulated chariots in 1796 to this June, for the holdings that belong in your next agreement.

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October 2026

China · Global tax trends · Cross-border families

The Bill Follows You

Beijing has given residents until October 22 to settle back tax on offshore trusts funded since 2023, and it is the sharpest example of a pattern visible on most continents, as governments reach for the people who have money through residence tests, deemed sales, and automatic data exchange rather than through the assets themselves.

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September 2026

ETF conversions · Tax-aware funds · IRS guidance

Good Enough to Be True

On September 28 the IRS ruled that a §351 ETF conversion built on an integrated contribution-and-redemption plan is a taxable exchange, and flagged seven related fund strategies for comment by October 28. The holding reaches only the stock that left the fund, not the whole conversion, so the number that matters is the lot-level record, not the headline.

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September 2026

Tax administration · Artificial intelligence · Partnership audits

Fewer Agents

The AICPA and former IRS Commissioner Danny Werfel have launched a Council on AI Risk in Tax just as the agency leans harder on software with far fewer people to run it. A correct return can still be expensive to defend when a screen, or a newer examiner, cannot connect two numbers that were reported correctly all along.

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September 2026

Capital solutions · Hybrid capital · AHYDO · Section 163(j) · PIK · Withholding tax

The Space Between

A sponsor needs $100 million, the senior lenders will not advance it, and a capital-solutions fund offers a note or preferred stock that both appear to buy time. The price of that time is harder to see. We follow one hypothetical company, Northline Services, from financing to exit and land on three answers, one per seat at the table, none of them free, all of them negotiable if you catch them before the term sheet is signed.

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September 2026

Airport art · Transport history · Percent-for-art programs · VARA

Look Up

Our first client note with nothing to do with your K-1. A history of art in transit, from the Doge of Venice's gilded ceremonial barge to the 32-foot fiberglass horse with glowing red eyes that guards Denver International (residents call him Blucifer; he has never lived it down). Along the way: stagecoach doors painted like small traveling galleries, a Calder mobile that survived a commissioner who thought it belonged in a museum instead of an airport (he was half right — the airport became one), and a Frank Stella painting bought for $25,000 that is now worth roughly $8 million, which is either the best art advice or the best financial advice we have ever accidentally given. One question follows the whole story: who paid for the art, and what did they think they were buying?

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September 2026

Wealth tax · Taxpayer mobility · Proposition 40 · §877A · Expatriation

The Closed-System Fallacy

HMRC has put a named compliance manager on every billionaire it has identified with a UK tax connection, filer or not, and on November 3 Californians vote on a one-time 5% tax on billionaire net worth keyed to a residency date already behind us. The mobility data carry real labels, not the ones usually quoted, and the reference dates deserve attention while a proposal is still a proposal.

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September 2026

Pass-through entity tax · SALT cap · Investment partnerships · Carried interest · §164

No Trade or Business Required

Investment funds and carried-interest vehicles can elect the pass-through entity tax, deduct it, and defend it. A state income tax is a §164 item, not a §212 expense, and nothing in §164, §703, the regulations, or Notice 2020-75 asks whether the partnership is in a trade or business. Two worked cases, a state-by-state eligibility table, and five questions to settle before you sign. A technical companion carries the reporting walkthrough, the allocation exhibits, and the answers to the objections.

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September 2026

§882 · Effectively connected income · Loan origination · Agency attribution

Nor a Lender Be

A two-page reading of Stevens and Weinreich (EY), "Nor a Lender Be," Tax Notes Federal, September 2, 2026. Two factors decide whether a platform's origination work is attributed to a non-U.S. investor: influence over terms and the power to bind. Six market scenarios mapped, and what we would build the file around.

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September 2026

Firm news · Capital solutions · Private credit

La Presa advises Trimontium on $325 million capital solution for Authentic Restaurant Brands

La Presa Partners served as tax adviser to Trimontium on a bespoke $325 million package of debt, hybrid, and equity instruments for Authentic Restaurant Brands, a portfolio company of Garnett Station Partners.

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September 2026

Tax KPIs · CFO perspectives · Tax function performance

A Funny Thing Happened to the KPI

A CFO's guide to measuring a tax department: a mandate map, a five-dimension scorecard, ten principles (the tenth courtesy of the derivatives desk), the metrics to distrust, and a 100-point starting framework.

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August 2026

Continuation funds · §704(c) · Rollover · Secondaries

The Second Exit

What the cashing-out LP, the rolling LP, and the new money each give up when a sponsor moves a company into a continuation vehicle, with the basis and liability arithmetic laid out step by step.

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August 2026

Structured finance · Private credit · Blockers · Insurance capital

Private Markets Meet Structured Finance

What a collateralized fund obligation is, why Franklin Templeton's first one matters more than its size, how the economics work through a simple example, and the questions an investor should ask before buying in, from waterfall position to valuation control to tax treatment.

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August 2026

Self-employment tax · §1402(a)(13) · Investment managers · Soroban

The Fifth Circuit Rewrites Sirius

On August 12 a divided Fifth Circuit panel withdrew its January Sirius Solutions opinion and substituted a management-based test for who counts as a "limited partner." The taxpayer kept its remand; everyone else lost a bright line. What changed, what it costs, and what sponsors should do now.

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