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
Q: I have a client who owes money to the IRS. While I know the IRS likely has a tax lien, my understanding was it just waits until a taxpayer’s property is sold and then gets paid out of escrow. Instead, here, the IRS has...more
The following is a review of notable cases and regulatory developments for nonprofit organizations at the federal and state levels during the last two years....more
I have been a major fan of Afro-Cuban (Salsa) and Brazilian Bossa Nova music since high school. Most of you know by now that I grew up in the Panama Canal Zone. By the time I got to West Point in the summer of 1978, it was...more
CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
As covered in an earlier client alert by our firm, The Federal Trade Commission (FTC)’s final Non-Complete Clause Rule—if it survives legal challenges and becomes effective—would ban most post-employment non-compete...more
The Biden Administration’s new corporate tax increase proposal will face substantial challenges in both branches of Congress this year. The IRS continues to focus on the tax profiles of large corporations, limited...more
Decentralized Finance (DeFi) is an umbrella term used to describe financial services provided outside of the traditional markets, that rely on blockchain technologies to create innovative products instead of relying on...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline. Culp v. Commissioner is the first case in...more
On July 19, 2023, the United States Court of Appeals for the Third Circuit released an opinion in the matter of Culp v. Commissioner of Internal Revenue (PDF). The ruling stated the 90-day filing period for Tax Court...more
Today, the Supreme Court of the United States issued six decisions: Amgen Inc. v. Sanofi, No. 21-757: This case addressed the Patent Act’s “enablement” requirement—the provision that requires a patent applicant to describe...more
In a prior post, we discussed the FTC’s recently-issued Proposed Rule that would, if finalized in its current form, and with only limited exceptions, prohibit employers from using non-compete clauses. With respect the...more
Summary: XC Foundation (“XC”) was incorporated in California in 2007. In 2008, the IRS issued XC a determination letter recognizing it as exempt from federal income tax under section 501(c)(3) and as a private foundation...more
Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary: Eric Schwartz (“Schwartz”) and his spouse divorced. Pursuant to those divorce proceedings, the state court...more
Today, the Supreme Court of the United States granted certiorari in four cases: Coinbase, Inc. v. Bielski, No. 22-105: This case presents an issue of federal arbitration law. The question presented is: Whether a...more
The Mid-Terms- With 50 seats in the Senate, the Dems still control that Chamber. A win in the Georgia runoff, however, may lessen the burden for Majority Leader Schumer by, perhaps, neutralizing the significance of a certain...more
Tax Litigation: The Week of August 1st, 2022, through August 5th, 2022 Eze v. Comm’r, T.C. Memo. 2022-83 | August 4, 2022 | Lauber, J. | Dkt. No. 21425-19...more
Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more
Collection Due Process Hearings and Jurisdiction Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before...more
Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more
This week, the Ninth Circuit explores whether Twitter’s conflict with the Texas AG’s office over content moderation was ripe for review and when taxpayers may deduct mortgage interest payments after a short sale. ...more
Multiple federal tax cases continue to make their way to the U.S. Supreme Court, and it has certainly been interesting to monitor changes and updates to the Court’s docket. I previously wrote a blog on the oral arguments held...more
In the tax universe, deadlines are normal and expected. Most Americans are familiar with income tax filing deadlines (e.g., April 15th), and businesses are familiar with employment tax deadlines (e.g., January 15th)....more
Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more