§ Insights Tax · Risk · Strategy
Notes from the practice.
The regulatory updates, market commentary, and practical takeaways we’d share with a client on the phone — written by the partners doing the work.
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The first word.
Insights update · RSK-2026-07
F reorganizations in
S corporation deals.
S corporation deals.
Tax · Federal · M&A
F reorganizations in S corporation acquisitions: how Rev. Rul. 2008-18 works.
A pre-closing F reorganization lets the buyer of an S corporation obtain a cost basis in the assets, protects it if the S election was invalid, and lets sellers roll over equity on a tax-deferred basis. How it compares with §338(h)(10) and §336(e) elections.
Read the articleEarlier
Insights update · RSK-2026-06
California taxes
SaaS and software in 2027.
SaaS and software in 2027.
California sales tax on SaaS and software begins January 1, 2027.
Insights update · RSK-2026-05
Rev. Proc. 2026-32:
R&E and construction methods.
R&E and construction methods.
IRS expands automatic method changes for R&E expenditures and residential construction contracts.
Insights update · RSK-2026-03
IEEPA tariff refunds:
claims and tax treatment.
claims and tax treatment.
IEEPA tariff refunds: claims process and key income tax considerations for importers.
Insights update · RSK-2026-04
Texas franchise tax
adopts bonus depreciation.
adopts bonus depreciation.
Texas franchise tax adopts current IRC conformity and allows bonus depreciation.
Insights update · RSK-2026-02
The marginal well credit
just hit a record.
just hit a record.
The marginal well credit just hit a record. Here’s how to claim it.
Pillar guide · RSK-2026-01
The One Big
Beautiful Bill, decoded.
Beautiful Bill, decoded.
The One Big Beautiful Bill Act: what Texas business owners actually need to know.
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