The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
On April 25, 2024, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) published final regulations concerning the definition of domestically controlled qualified investment entities (DC-QIE) (the...more
In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
When the New Jersey Limited Liability Company Act originally went into effect in January 1994, the Internal Revenue Service required that a limited liability company have at least a majority of the characteristics of a...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
NY’s Almost There- Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability...more
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure - U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax filing and...more
More than two decades ago, the Service announced its intention to consider simplifying the entity classification rules in Notice 95-14. It stated: “The Internal Revenue Service and the Treasury Department are considering...more
More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more
In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 11, 2021 – October 15, 2021... October 12, 2021: The IRS released a notice, announcing...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 13, 2021 – September 17, 2021... September 13, 2021: The IRS issued a news release...more
Monetizing a business concept presents numerous considerations for ambitious entrepreneurs, but with careful forethought, founders can spend more time growing their business and less time worrying whether they made an...more
Effective January 1, 2021, Portland-metro residents and businesses need to be aware of two new taxes. The first is the Metro Supportive Housing Services Tax (“Metro Tax”), which was formerly known as Measure 26-210. The...more
In August, the U.S. Treasury Department and the Internal Revenue Service issued final regulations on the deductibility of payments of cash or in-kind donations to certain tax-exempt organizations if the donor receives in...more
A closely held business may come to our firm for any number of reasons. The owners may be selling the business, for example, or they may be thinking about spinning off a division. In some cases, the owners are considering the...more
At the end of June, the Commissioner of the IRS Large Business and International Division announced a new campaign to audit high-net-worth individuals and the entities (such as partnerships, corporations, trusts, and private...more
Due to COVID-19 closures at the Internal Revenue Service (IRS), EIN applications that are submitted by telephone, fax or mail currently are not being received or processed. Accordingly, non-U.S. applicants (who generally are...more
The IRS’ new policy regarding employer identification numbers (“EINs”) could significantly delay the formation of new entities, especially by non-U.S. persons, unless practitioners and their clients get very proactive. ...more
On May 28, 2014, FASB and IASB jointly announced new financial accounting standards for revenue recognition, titled “Revenue from Contracts with Customers (Topic 606).” For publicly-traded entities, Topic 606 was required to...more
In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more
In December, 2017 the Internal Revenue Service (IRS) released a revised Form SS-4, Application for Employer Identification Number and related instructions. An employer identification number (EIN) is a nine-digit number...more
In a General Information Letter addressing the tax treatment of benefit corporations, the Internal Revenue Service (IRS) stated that a taxable benefit corporation may deduct payments to charities as business expenses (and...more