Mark Miller

Mark Miller

Bradley Arant Boult Cummings LLP

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Changes to IRS Partnership and LLC Audit Rules

Recent history has seen a proliferation of health care organizations—including tax-exempt organizations, for-profit companies, and physician practice groups—that have joined together to take advantage of different synergies...more

4/26/2016 - Audits Bipartisan Budget Business Taxes Income Taxes Indemnification IRS LLC Operating Agreements Partnership Agreements Partnerships

Beware New IRS Partnership/LLC Audit and Assessment Rules

You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The new rules apply to tax years...more

3/10/2016 - Audits IRS Limited Liability Companies Partnerships Tax Planning

IRS Audits of Partnerships: Big Changes are Coming

The Bipartisan Budget Act of 2015 (the “Act”), which was signed into law on November 2, will drastically change the way entities (including limited liability companies) treated as partnerships for U.S. federal income tax...more

11/17/2015 - Audits Bipartisan Budget Business Taxes IRS LLC Partnerships Tax Liability

IRS Releases Guidance on Taxability of Identity Protection Services

As companies and governmental entities increasingly do business and store sensitive information in online or cloud-based environments, the risk of improper disclosure continues to grow. The unprecedented breach of the United...more

8/18/2015 - Financial Institutions Identity Protection Services Identity Theft IRS OPM Personally Identifiable Information Popular Tax Liability

Implications of Final Regulations Under Internal Revenue Code Section 501(r)

The Internal Revenue Service replaced proposed regulations under Section 501(r) of the Internal Revenue Code (the “Code”) with final regulations in late 2014 (the “Final Regulations”). As enacted in the Patient Protection and...more

2/12/2015 - Affordable Care Act CHNA Exempt Organizations Financial Assistance Policies Healthcare Hospitals Internal Revenue Code (IRC) IRS Proposed Regulation Section 501r

State & Local Tax Alert: Alabama Edition - September 25th, 2013

The Alabama Historical Commission has issued emergency regulations to implement the state’s new historic structures rehabilitation tax credit. Emergency Rules 460-x-23-.01ER through 460-x-23-.13ER took effect September 1,...more

9/25/2013 - Historical Landmarks SALT Tax Credits

How “Taxing” Does a Patent Transfer Have to Be?

Whether you are transferring patent or acquiring rights in a patent, the tax consequences can vary greatly depending on how the transfer is structured. The IRS has recently issued a document (Legal Advice by Field Attorney...more

8/30/2013 - IRS Licenses Patents Sales Transfer Taxes

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