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
Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more
When the IRS published proposed regulations harmonizing key provisions of Code Sections 409A and 457(f) in 2016, executive compensation lawyers and consultants rejoiced. It was not just that a long wait was over (roughly nine...more
On this episode of “Just Compensation,” the hosts provide an introduction into Section 409A, the complicated tax code provision that governs non-qualified deferred compensation: when does it apply, how do you comply with it,...more
As part of our ongoing series on tax issues for accounting firms, this article provides information on retirement or deferred compensation arrangements, the related rules of Section 409A of the Internal Revenue Code, and how...more
Section 409A of the Internal Revenue Code of 1986, as amended (409A), was enacted into law in 2004 to impose statutory requirements on “nonqualified deferred compensation plans, programs or arrangements” (collectively...more
In this episode, the hosts discuss how companies can structure “in-the-money” stock options in order to avoid violating IRS rules governing non-qualified deferred compensation. They also address the benefits and potential...more
Americans hold a considerable percentage of their wealth in retirement accounts. Recent changes to the Internal Revenue Code (the “Code”), as well as proposed regulations, have introduced new rules altering the required...more
Readers who regularly work with deferred compensation plans will know that Section 409A of the Internal Revenue Code (“Section 409A”) prescribes six events or times at which deferred compensation may be distributed to...more
On March 28, the Biden Administration submitted its Fiscal Year 2023 budget proposals reflecting its budget and tax policy priorities, which could surface when Congress resumes work on budget reconciliation. While it is...more
Tax Litigation: The Week of February 21, 2022, through February 25, 2022 - Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23, 2022 | Gale, J. | Dkt. No. 10406-17 - Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23,...more
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A...more
Twenty years ago this month the Enron Corporation imploded in spectacular fashion and declared bankruptcy. In the weeks leading up to its bankruptcy filing, over 100 highly compensated employees raced to receive early...more
The IRS updated its Nonqualified Deferred Compensation Audit Techniques Guide (the “2021 Guide”) in June 2021. The 2021 Guide replaces a similar guide that was published in June 2015. The 2021 Guide does not shed new...more
Pubic companies that sponsor nonqualified deferred compensation plans with grandfathered benefits will want to be aware of helpful payment guidance in the Internal Revenue Code Section 162(m) final regulations. The final...more
Public companies that sponsor nonqualified deferred compensation plans that require Internal Revenue Code Section 162(m) payment delays may want to consider whether removing the payment delay provision from a plan is...more
The Internal Revenue Code is famously complicated, and changes to discrete parts of the code - such as those adopted by the Tax Cuts and Jobs Act of 2017 (TCJA) - have a notorious history of leading to unpredictable and...more
A special IRS-approved correction method available for elective deferral failures in 401(k) and 403(b) plans with automatic contribution features will sunset on December 31, 2020, meaning it will not be available to correct...more
Certain deferred compensation plans and agreements maintained by publicly held corporations and subject to Section 409A of the Internal Revenue Code may need to be amended before December 31, 2020, to reflect changes in the...more
Public companies maintaining deferred compensation arrangements for their executive officers should consider how recent changes to the regulations under Section 162(m) of the Internal Revenue Code (the Code) may impact the...more
The coronavirus pandemic has caused widespread economic uncertainty and unanticipated liquidity issues for a wide range of individuals, including plan participants of nonqualified deferred compensation plans. In these...more
Transition relief for amending nonqualified deferred compensation (NQDC) plans to reflect the 2017 amendments to Section 162(m) of the Internal Revenue Code will expire on December 31, 2020. ...more
In response to the unprecedented worldwide COVID-19 pandemic, businesses are turning to cash flow issues resulting from the abrupt economic downturn. Companies are looking to reduce operating costs and employees are...more
Recently issued proposed regulations clarify changes made by the TCJA to the tax deductibility of executive compensation. Section 162(m) of the US Internal Revenue Code (the Code) as amended by the Tax Cuts and Jobs Act...more
There are several tools that can be used to correct or fix governmental plan problems. First, some classification. Practically all the retirement plans we discuss are “tax-advantaged” in one form or another. However,...more
Earlier this week, the Internal Revenue Service’s Large Business & International Division announced six more compliance campaigns, bringing the total number of campaigns announced to date to a whopping 59. These campaigns...more