Nonprofit Quick Tip: State Filings in Massachusetts and Connecticut
EV Tech Series: The Inflation Reduction Act’s Impact on the Energy Industry With Judy Kwok and Marc Machlin - Battery + Storage Podcast
Tribal Tax Exemption Under McGirt Gains Preliminary Victory
Taking the Sting Out of Death Taxes with Dylan Metzner, Jones & Keller
ATTENTION ALL CADETS!
One Note Samba
Podcast: State Taxation of Digital Health Products
Investment Management Roundtable Discussion – Personal Estate Planning
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Podcast: Credit Funds: The Benefits, Challenges and Applications of Treaty Fund Structures When Investing in Credit
Podcast - New Unrelated Business Taxable Income Liability for Providing Certain Fringe Benefits
Episode 26: Talking Tax Reform and Executive Comp
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
New York Estate Tax Law Changes
With continuing uncertainty regarding the federal estate tax laws, the Spousal Lifetime Access Trust (SLAT) is a popular option that helps high net-worth individuals maintain flexibility while maximizing their financial...more
As we recently reported, in its Final Rule banning most worker non-competes, the Federal Trade Commission (“FTC”) previously warned of its intent to vigorously enforce its non-compete ban wherever possible, which may include...more
I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more
When considering compensation and benefits packages to lure and retain top executives or talent, nonprofit organizations, including universities and hospitals, are often at a disadvantage compared to their for-profit rivals....more
Section 6417 of the Internal Revenue Code was added by the Inflation Reduction Act of 2022 (IRA). The section provides that eligible taxpayers may make an election to claim certain clean energy credits even though they have...more
On April 18, 2024, the Financial Crimes Enforcement Network (FinCEN) released further guidance regarding to Corporate Transparency Act compliance (CTA) by updating and expanding the Beneficial Ownership Information Reporting...more
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
In September, Treasury announced forthcoming guidance that will clarify whether the limited partner exception applies to limited partners that actively participate in their businesses....more
The Long-Term View- Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more
A trust structure, commonly used for estate planning, can be problematic in certain civil law jurisdictions, such as those in many European countries. Recent acts enacted in Wyoming and New Hampshire allow for the...more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
Beginning on January 1, 2024, the vast majority of new and existing business entities will become subject to beneficial ownership information reporting requirements under the Corporate Transparency Act and its related rules...more
Most founders are familiar with Section 1202 of the Internal Revenue Code, which provides a tax exemption for the sale of Qualified Small Business Stock (QSBS). Less well known is Section 1202's cousin, Section 1045, which...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
Sometimes the first step to solving (or mitigating or avoiding) problems is to identify what the problem may be to, among other things, put time on one’s side. For issuers of tax-exempt municipal bonds, there tend to be...more
Part 1: Permitted Investments and Compliance - The self-directed individual retirement account (IRA) is an increasingly popular option for an IRA account owner, especially those owners who have significant net worth and...more
A corporation’s net operating losses (NOLs)are important assets that can be used to reduce future taxable income. But certain changes in a corporation’s ownership can significantly reduce the value of those NOLs....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023. July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30,...more
The Inflation Reduction Act of 2022 added Section 6417 to the Internal Revenue Code of 1986, as amended (the “Code”). Under this new section, certain taxpayers may elect to receive a direct payment in lieu of certain energy...more
The IRS and Treasury have issued proposed Treasury Regulations concerning the newly enacted Internal Revenue Code section 6418 which allows eligible taxpayers to sell most clean energy tax credits to unrelated third parties...more
Summary - The IRS recently advised that many organizations that develop paid name, image, and likeness—known as NIL—opportunities for college student-athletes are not eligible for tax-exempt status under Internal Revenue...more
On Wednesday, June 14, 2023, the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) issued proposed Treasury Regulations on the elective payment of certain tax credits (also known as direct pay) under...more
On June 9, 2023, the IRS issued memorandum number AM 2023-004, providing guidance on whether organizations that develop paid name, image, and likeness (NIL) opportunities for student-athletes are tax-exempt under section...more
A number of our clients have recently inquired as to their responsibilities with respect to arbitrage rebate for their tax-exempt borrowings. The dramatic increase in the return on short-term investments is raising the...more