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
For nearly 40 years and in more than 18,000 judicial opinions, federal courts have used the Chevron doctrine to defer to an agency's reasonable interpretation of an ambiguous statute. On June 28, 2024, the U.S. Supreme Court...more
The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more
On July 23, 2024, the United States Court of Appeals for the District of Columbia Circuit (Court of Appeals) released a decision in Rawat v. Commissioner (available here). The case considers whether the portion of a non-US...more
On June 28, 2024, in Loper Bright Enterprises v. Raimondo, the U.S. Supreme Court overruled its decision from a 1984 case and eliminated the doctrine of “Chevron deference.” Under this doctrine, courts deferred to permissible...more
In a historical opinion in Loper Bright Enterprises v. Raimondo, Secretary of Commerce, released at the end of June, the U.S. Supreme Court overturned the “Chevron” doctrine, which for so long had controlled judicial review...more
On June 28, the U.S. Supreme Court sent shockwaves through the legal system by overturning one of the foundational precedents of American administrative law. In Loper Bright Enterprises v. Raimondo, the Court, in a 6-3...more
Upon closing its October 2023 term, the U.S. Supreme Court issued two significant opinions – despite neither being a tax case – that will have broad consequences for taxpayers seeking to challenge tax regulations and other...more
On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more
In a landmark decision, the Supreme Court has overruled the Chevron doctrine, fundamentally altering the landscape of administrative law and significantly impacting federal tax administration. Six justices, with Chief Justice...more
Construction Industry Wage-and-Hour Issues: 6 Tips for Laying a Foundation of Compliance - The construction industry feeds a significant part of the U.S. economy, providing millions of short- and long-term jobs across the...more
The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
On November 2, 2022, the Supreme Court of the United States announced that the case of Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9, has been distributed for consideration at...more
In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like they do to other federal agency...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
In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more
In recent guidance, the Department of Treasury and the IRS issued proposed rules that clarify under the Internal Revenue Code (Code) that the terms “spouse” and “husband” and “wife” refer to individuals who are lawfully...more
Editor's Overview - It has been a little more than one year since the U.S. Supreme Court altered the legal landscape for litigating ERISA breach of fiduciary duty claims relating to the investment in employer stock...more
Editor's Overview - As the summer draws to a close, this month's Newsletter previews three cases that the U.S. Supreme Court already has agreed to hear that ought to be of particular interest to ERISA plan sponsors and...more
Part I: Is PPACA on the Road to Recovery? The recent decision in King v. Burwell by the Supreme Court of the United States sent a strong message to critics of the Patient Protection and Affordable Care Act of 2010...more
In recent months employers around the country, have been scrambling to keep up with developments with respect to the evolving rights of employees in same-sex relationships. This articles touches on some recent guidance in...more
In its latest addition to guidance concerning the effects of the U.S. Supreme Court's decision in United States v. Windsor, the Internal Revenue Service ("IRS") has issued Notice 2014-1 to address certain issues relating to...more
In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home Concrete. ...more
Notice 2013-61 provides alternative administrative procedures for reporting income and FICA tax adjustments in response to the Windsor decision and Revenue Ruling 2013-17. On September 24, the U.S. Department of the...more
A few weeks after the Internal Revenue Service (IRS) stated that it will apply a “place of celebration” rule in recognizing same-sex spouses for purposes of the Internal Revenue Code (including with respect to employee...more
On August 29, 2013, the Treasury Department and the Internal Revenue Service issued a public announcement and released Revenue Ruling 2013-17 wherein it answered a number of open questions concerning the impact of the U.S....more