Part VII · Reference · No. 04

What has changed

A dated record of additions, revisions, and corrections, in reverse chronological order. Where a change reflects new law, the underlying authority is identified; where it reflects an editorial correction, the substance of the correction is described.

This changelog is the single place to confirm when a given entry was last touched and what was done to it. The "Reviewed" line at the foot of each entry restates the most recent review date for that page; this changelog provides the narrative.

Editorial notes for future reviews

Several recurring items will appear in future changelog entries. The following are flagged for attention at the next annual sweep:

• Estate-tax exclusion sunset. The doubled basic exclusion amount enacted in 2017 sunsets at the end of 2025 absent further legislation. Entries discussing estate tax, GST trusts, and lifetime gifting strategies will be reviewed as legislation develops.
• Corporate Transparency Act litigation and rulemaking. The beneficial-ownership page tracks ongoing litigation over the CTA's constitutionality and any FinCEN rule changes. Recent injunctions and interim final rules have produced a regime in flux; the page will be revised on any material development.
• Opportunity-zone deferral expiration. The opportunity zones entry notes that the §1400Z-2 deferral expires for taxable years beginning after December 31, 2026, with inclusion in 2026. The entry will be updated if Congress extends or modifies the regime.
• FATCA and CRS developments. Any change in U.S. participation in CRS or in the FATCA reciprocity framework will be reflected on the FATCA page.
• State residency enforcement. The state residency page tracks New York, California, and Massachusetts statutory-residence enforcement trends; new audit guidance from any of these states will prompt a review.
• Italian new-resident flat tax. The amount of the annual substitute tax under Article 24-bis TUIR was increased by the Italian government for new electors after a recent budget law. The Italy entry reflects the current figure as of the review date.

How to read an entry on this changelog

Each entry has three elements: the date in ISO form; a short headline identifying the change; and a paragraph describing what changed and, where applicable, the authority. Substantive corrections to law are distinguished from editorial corrections (typography, broken links, reorganization). Reviews that produced no substantive change are recorded simply with the date and the page title.

Reporting an error

Errors of law are corrected on identification, with the correction recorded on this page and the "Reviewed" line of the affected entry updated. Where an error is identified after publication, the changelog entry will note the original wording and the corrected wording so that the record of the change is preserved.

Reviewed May 2026