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
The Tax Cuts and Jobs Act (TCJA), which became effective on January 1, 2018, made significant changes to tax legislation that impacted individuals, families, business owners and companies. Some changes were intended to be...more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Businesses often manage their price risks by hedging those risks with financial derivative contracts. Because businesses generate ordinary income and loss on their normal business activities, they want to be sure their...more
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more
On April 21, 2023, the Internal Revenue Service (IRS) released a Chief Counsel Advice memorandum (ILM 202316008), concluding that a protocol upgrade to the consensus mechanism of a cryptocurrency blockchain that did not...more
Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more
Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more
Deal Costs, Generally- Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more
Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Spencer v Commissioner, T.C....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 9 – August 13, 2021 - Manuelito B. Rodriguez &...more
Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more
The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more
On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more
On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more
The IRS issued final QOZ regulations at the end of 2019, almost two years after Qualified Opportunity Zones (“QOZs”) were introduced to investors in the 2017 Tax Cuts and Jobs Act. These regulations finalized the proposed...more
On October 9, 2019, the Internal Revenue Service (IRS) issued long-awaited guidance relating to transactions involving virtual currencies, such as cryptocurrencies. Aligned with the agency’s continuing efforts to enforce tax...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more
Proposed regulations under Section 864(c)(8) provide guidance for determining a foreign partner’s effectively connected gains or losses from a transfer of its interest in a partnership engaged in a US trade or business. ...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
The year 2017 could be described as the year of the Bitcoin and other “virtual currencies,” with Bitcoin having appreciated 1800% since the beginning of the year and Ethereum, at one point, having appreciated 8,000% since the...more