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Internal Revenue Service Corporate Governance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Saul Ewing LLP

Public Companies Quarterly Update (Q2 2024)

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Welcome to Saul Ewing’s Public Companies Quarterly Update series. Our intent is to, on a quarterly basis, highlight important legal developments of which we think public companies should be aware. This edition is related to...more

Latham & Watkins LLP

IRS Launches New Large Partnership Audits, Relying on AI and Increased Funding

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The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more

Farella Braun + Martel LLP

Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In episode 82, we revisit the duties of directors in managing investment assets. Joining Cynthia Rowland today is Jennifer Nelson, Senior Wealth Manager with BNY...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more

Buckingham, Doolittle & Burroughs, LLC

Gifts of Private Company Interests to Charity Prior to Sale

A planning technique that is known to most tax professionals is for an owner of a private company to gift an interest therein to charity prior to a sale. This technique is only of interest to taxpayers who are charitably...more

PilieroMazza PLLC

Focus on S Corporations, Part 2: Inadvertent Termination of S Corporation Elections

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The IRS recently provided guidance addressing inadvertent terminations of S Corporation (S Corp) status based on existing provisions in corporate documents that remain after a company makes an S Corp election. This can be a...more

PilieroMazza PLLC

Focus on S Corporations, Part 1:  Choosing the Right Entity to Meet Your Small Business Goals

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Most business owners understand the need to create an entity to operate their business. However, beyond general knowledge, many owners are unsure of when is the right time to create an entity and which type of entity makes...more

Stark & Stark

Don’t Let Your LLC Expire: LLC Owners Should Check Formation Documents to Confirm Perpetual Duration

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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

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Expands Scope of Private Letter Ruling Program for Spin-Offs and Other Corporate Transactions

On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more

Dorsey & Whitney LLP

Canadian Compensation Arrangements - When Do I Need U.S. Counsel?

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Imagine a Canadian company adopts a deferred share unit plan (DSU Plan) for its directors.  At the time the plan is adopted, the company does not have the plan reviewed by U.S. counsel, because none of their directors reside...more

Skadden, Arps, Slate, Meagher & Flom LLP

Real World Examples Where Conflicts Tainted a Deal Process, and Other Deals That Were Insulated From Conflicts

Sometimes when a board is considering a strategic transaction, it may find that a key figure who can influence the deal process — for example, a founder, controller or CEO-negotiator — has a potential conflict of interest....more

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Fall 2023

Boards routinely confront an array of difficult issues. In this issue of The Informed Board, we tackle four of the thorniest and most topical: - How to preserve the integrity of a deal process where a key fiduciary (say,...more

Morrison & Foerster LLP

U.S. Attorney for the Central District of California Announces a New Corporate and Securities Fraud Strike Force to Ramp up...

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On October 4, 2023, Martin Estrada, U.S. Attorney for the Central District of California (CDCA), announced the formation of a Corporate and Securities Fraud Strike Force (the “Strike Force”), a new CDCA section designed to...more

Farella Braun + Martel LLP

Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut

Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and episode 55 is the sixth in a series of Quick Tip episodes focusing on the details of state registration of nonprofit corporations. In...more

Wilson Sonsini Goodrich & Rosati

Sustainability and ESG Advisory Practice Update, June 2023

SEC Publishes Spring 2023 Regulatory Agenda - On June 13, 2023, Chair of the U.S. Securities and Exchange Commission (SEC) Gary Gensler announced the release of the SEC’s Spring 2023 Regulatory Agenda (the Regulatory...more

A&O Shearman

Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure

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On May 3, 2023, the Tax Court released a memorandum opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a profits interest in a lower-tier partnership qualified as a non-taxable event...more

Goodwin

Stock Buybacks: Recent Developments and Hot Topics for Issuers

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Increased equity market volatility provides issuers with opportunities to repurchase shares at attractive prices. At the same time, issuers must consider how recent changes to the tax treatment of stock buybacks, potential...more

Holland & Hart - The Benefits Dial

Should I Pay Or Should I No(t) Now: Which Expenses Can be Paid with Plan Assets?

One question that often comes up is whether an expense related to an ERISA plan can be paid with plan assets. The decision of whether to use ERISA plan assets to pay an expense is an ERISA fiduciary decision. With the recent...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden’s 2023 Insights – Five Critical Areas for the Year Ahead

The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more

Fuerst Ittleman David & Joseph

FinCEN Issues Final Rule for Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act

On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) promulgated its much-anticipated Final Rule implementing the beneficial ownership reporting scheme mandated by the Corporate Transparency Act....more

Freeman Law

The Alter Ego Doctrine and Taxes

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The Alter Ego Doctrine and Taxes What is an “alter ego?” The phrase is Latin, translating to “second I,” “another I,” or “other self.” In the federal tax context, the alter ego doctrine comes into play where the IRS...more

Rivkin Radler LLP

[Webinar] Lunch & Learn Series: A Refresher on Form 990: Tips and Traps for Tax-Exempt Organizations - April 14th, 12:00 pm - 1:00...

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Please join us as Louis Vlahos and Bernadette Kasnicki provide a refresher on preparing Form 990, the tax return for tax-exempt organizations. We will review…...more

Latham & Watkins LLP

7 Steps for Success After Forming a Section 501(c)(3) Organization

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Section 501(c)(3) status comes with a number of operational and compliance requirements that must be followed in order to maintain federal income tax exemption. This guide highlights key Section 501(c)(3) requirements that...more

Holland & Knight LLP

Holland & Knight's China Practice Newsletter: November-December 2021

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Holland & Knight invites you to read our China Practice Newsletter, in which our authors discuss pertinent Sino-American topics - HIGHLIGHTS: Preference Claims Clawbacks in Bankruptcy Can Disrupt a Construction...more

Foodman CPAs & Advisors

2021 “Green Book” Introduces Comprehensive Financial Account Reporting

The “Green Book” is a US Treasury Department document that presents detailed explanations of an Administration’s revenue proposals in support of a President’s annual budget request.  On May 28, 2021, the Biden administration...more

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