The IRS and Treasury Department have released proposed regulations to reflect the holdings of Obergefell v. Hodges, 135 S.Ct. 2584 (2015).  In Obergefell the U.S. Supreme Court held that state laws are “invalid to the extent they exclude same-sex couples from civil marriage on the same terms and conditions as opposite-sex couples.”  In addition to providing that the terms “husband” and “wife” should be interpreted in a neutral way to include same-sex spouses as well as opposite-sex spouses when used in the Code, the proposed regulations provide that a marriage of two individuals is recognized for federal tax purposes if the marriage would be recognized by any state, possession, or territory of the United States.