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
Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2024 deadline for paying fees that fund the Patient-Centered Outcomes...more
On March 27, 2024 the Vermont Captive Insurance Association (VCIA) held its biannual “Roadshow” educational event designed for prospective captive insurance companies. The Roadshow, which has been hosted in over 20 cities,...more
Our Tax Group sheds light on recent IRS rulings that disallow deductions involving success-based fees in M&A transactions. Contrary to common practice, the IRS recently ruled target companies could not deduct success-based...more
“Georgia” on your mind? As we look towards the upcoming Masters golf tournament weekend, our minds turn to the condition of the greens (exquisite), the players tee off order (does afternoon help or hinder Tiger on an expected...more
The Internal Revenue Service, Employee Benefits Security Administration, and the Centers for Medicare & Medicaid Services (collectively, “the Departments”) recently issued final rules concerning fees established by the No...more
The IRS recently published a private letter ruling (No. 202341002) dealing with the tax treatment of advisory fees paid to an adviser from an “adviser life insurance contract.” Specifically, the letter ruling addressed...more
The Pitch newsletter is a monthly update of legal issues and news affecting or related to the music, film and television, fine arts, media, professional athletics, eSports, and gaming industries. The Pitch features a diverse...more
On October 18, the IRS issued Notice 2023-70, which increased the PCORI fee from $3 per covered life to $3.22 per covered life for policy and plan years that end on or after October 1, 2023 and before October 1, 2024....more
The IRS has released Notice 2023-70, which sets the applicable PCORI fee for plan years ending between October 1, 2023 and September 30, 2024 at $3.22 per covered life....more
The fee disclosure regulations were one of the best things that ever happened to the retirement plan business. Yet, what is great, can be improved....more
Was your community association lucky enough to come in under budget last year? On the surface, this might appear to be a bonus, but if not handled properly, it can quickly turn into an unexpected tax burden. ...more
In a recently released bulletin, IR-2023-59, the IRS warns of shady tax preparers and increased audit risk as part of their “Dirty Dozen” series. The IRS provided some common “warning signs” including tax preparers who base...more
In Private Letter Ruling 202308010 (PLR 20230810), the Internal Revenue Service (IRS) determined that a contingent sell-side advisory fee (the Fee) was incurred by the private equity fund majority seller (the PE Seller),...more
Registered investment advisers, including dual registrant broker-dealers (collectively “advisers”) who provide discretionary investment management services to individual retirement accounts (IRAs), are fiduciaries under the...more
What is the PCORI Fee? The Affordable Care Act created a non-profit corporation, the Patient-Centered Outcomes Research Institute (“PCORI”), to conduct research to help individuals, providers, and policymakers make better...more
When taxpayers pay fees contingent on the successful closing of certain “covered transactions,” including, for example, taxable acquisitions of assets that constitute a trade or business, such “success-based fees” must be...more
The annual filing (and fee payment) for applicable self-insured health plans and specified health insurance policies used to fund the Patient-Centered Outcomes Research Institute (the PCORI fee) is soon coming due—this year,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020... November 23, 2020: The IRS released TD 9935, providing...more
Transactions involving the borrowing and lending of units of virtual currency (or crypto loans) are increasing in number and type. Lacking Treasury or IRS guidance with respect to crypto loans, potential tax issues that arise...more
Seyfarth Synopsis: The IRS announced the new rate for calculating the PCORI fee and provided some transition relief, but did not extend the deadline of July 31st for paying the fee. In May, the IRS issued Rev. Proc. 2020-32...more
Yes, that PCORI Fee—it’s back! About this time last year, we let you know that this filing and fee was coming due, and that it was the last time it would be required for a calendar year plan. Since that time, however, the...more
Form 1023 Paper Submission Transition Period Expires April 30 - As of January 31, 2020, organizations are required to submit Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal...more
In the wee hours of December 2019, Congress revived the PCORI fee and filing obligations of employer sponsors of self-insured group health plans. In accordance with the requirements of the Affordable Care Act, employer...more
A recent Technical Advice Memorandum (TAM) issued by the Internal Revenue Service (IRS) National Office concludes that a target company required under Internal Revenue Code Section 263(a) regulations to capitalize costs that...more
In the summer of 2019, I wrote a short blog on the death of the PCORI fee — Ding, Dong, the PCORI Fee is Dead!. When enacted as part of the Affordable Care Act, the fee was set to expire with plan/policy years ending after...more