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Recent Tariff Developments: Changes to the Canadian Tariff List Under Section 338
The U.S.-Canada trade conflict has escalated significantly over the past several months, marked by the rollout of retaliatory tariffs and warnings of slowing economic growth. President Donald Trump signed a proclamation on October 23, 2026, modifying the 50% U.S. tariffs on Canadian imports under Section 338 of the Tariff Act of 1930, which takes effect…
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What Treasury’s New Single-Family Home Rules Could Mean for Real Estate Investors
The U.S. Treasury Department has proposed regulations that would implement the 21st Century ROAD to Housing Act, which restricts certain large institutional investors from purchasing single-family homes beginning January 7, 2027. Under the law, the restrictions generally would apply to an investor engaged in the business of investing in, owning, renting, managing or holding single-family…
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Section 351 ETF Conversions and Rev. Rul. 2026-20: What the Ruling Leaves Unanswered
Revenue Ruling 2026-20 and Notice 2026-62 address certain exchange-traded fund (ETF) and tax-aware investment fund strategies, including transactions involving Section 351 contributions. The ruling addresses an investor that, as part of a plan, contributes a diversified portfolio of appreciated securities to a newly formed ETF in an exchange intended to qualify under Section 351. Under…
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