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Exempt Organization Application Revisions and Required Electronic Submission

Earlier this year, the IRS revised Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions, to help charities apply for 501(c)(3) tax-exempt status. In...more

Tax-Free Rollovers in Private M&A Transactions: LLC Asset vs. Stock Drop-Down (with Examples)

Companies with a history of consistent revenue growth and adjusted EBITDA make attractive acquisition targets for strategic and private equity buyers. Unlike a strategic buyer, which may have on hand a management team capable...more

[Webinar] COVID-19 Comeback Convention - December 3rd, 8:30 am - 11:00 am ET

Insights and Ideas to Expedite Your Business Recovery in 2021 - Join us for the COVID-19 Comeback Convention, a virtual convention comprised of brief presentations tailored to meet the needs of senior executives and...more

[Webinar] Tax Planning: 2020 & Beyond - October 28th, 12:00 pm - 1:00 pm EST

2020 has been an uncertain year on many fronts. As we head towards year-end, we’ve seen an uptick of questions and concerns from our clients on navigating potential rate changes that could occur pending the outcome of the...more

[Webinar] M&A Webinar Series: Tax-Free Rollovers in Private Equity Transactions, hosted by Williams Mullen - June 23rd, 11:00 am -...

Do you often find yourself amid transactions that require a decision to sell a business to a private equity or other strategic buyer who are offering different consideration packages? Are you aware of the creative tax...more

IRS Issues Proposed Regs on Rehabilitation Credit

The IRS has released 26 CFR Part 1, resolving questions regarding the five-year period to claim rehabilitation credits for qualified rehabilitation buildings (QRBs).  Prior to the proposed regulation, practitioners were...more

IRS Denies Deduction for Forgiven PPP Loan Amounts Used for Business Expenses

In Notice 2020-32, released April 30, the IRS determined that expenses paid using the proceeds of Paycheck Protection Program (PPP) loans (Covered Loans) are not deductible expenses for income tax purposes if those loans...more

IRS Provides Additional Relief for Taxpayers Affected by COVID-19

On April 9, 2020, the Department of the Treasury (Treasury Department) and the Internal Revenue Services (IRS) issued Notice 2020-23, announcing that certain additional tax return filing and payment deadlines have been pushed...more

IRS Relief for Partnerships Wanting to Amend Tax Returns

On April 8, 2020, the Internal Revenue Service (IRS) released Revenue Procedure 2020-23 (the Revenue Procedure) allowing eligible partnerships subject to the centralized partnership audit regime (CPAR) to amend 2018 and 2019...more

CARES Act - Changes to TCJA Provisions and other CARES Act Business Tax Provisions

The Senate has negotiated and passed a third COVID-19 relief bill titled the “Coronavirus Aid, Relief, and Economic Security Act” (CARES Act). The bill will now head to the House for approval, and the President has agreed to...more

Treasury and IRS Move April 15 Tax Filing Deadline Amid COVID-19 Emergency

The April 15 deadline for filing tax returns will be postponed until July 15, after comments from Treasury Secretary Steven Mnuchin and Notice 2020-18 posted March 20 by the IRS. This news follows Secretary Mnuchin’s...more

Treasury Department Clarifies 90 Day Delayed Payment of Taxes Owed

Individuals can delay payments of up to $1 million in taxes and corporations can get payments of up to $10 million deferred until July 15 without interest and penalties, according to a notice published Wednesday. “Americans...more

Treasury Delays April 15 Deadline For Payment Of Taxes Owed

Treasury Secretary Mnuchin has announced that his department is pushing back the April 15 tax deadline. Individuals and businesses will be granted a 90 day extension to pay taxes they owe....more

Pass-through Deductions for Property Owners: New Clarity on Who Qualifies

As part of the 2017 tax overhaul, provisions were put in place that allowed those holding property for rental purposes to write off up to a fifth of their rental income for tax purposes. The deduction was included in Code...more

[Event] Spring 2018 Tax Forum - May 17th, Richmond, VA

Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 17, 2018. We will provide an overview of the impact of The Tax Cuts and Jobs Act and share our best practices on tax...more

Congress Passes Tax Act

On Wednesday, December 20, 2017, the legislation previously known as the “Tax Cuts and Jobs Act” (the “Act”) passed the United States House and Senate. At this juncture, it appears President Trump will sign the Act into law...more

Framework for Tax Reform Released

On September 27, 2017, the Trump Administration, the House Committee on Ways and Means, and the Senate Committee on Finance released a unified framework (the Framework) with the stated goal of achieving pro-American,...more

Trump Administration Releases Blueprint of Tax Reform

On April 26, 2017, the Trump Administration announced a blueprint of tax reform principles that is described as “The Biggest Individual and Business Tax Cut In American History.” The Administration identified four goals for...more

[Event] Spring 2016 Tax Forum - May 12th, 8:00 am, Richmond, VA

Please join us for the Spring Tax Forum to be held at the Williams Mullen Center on Thursday, May 12, 2016. Topics Include: Contributions of Property to a Partnership: An Analysis of Section 704(c) Methods Part II:...more

U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more

New Proposed Regulations Could Shake Up the Allocation of Partnership Debt

The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more

Revised Rev. Proc. 2014-12 Clarifies New Guidance on Rehabilitation Tax Credits

On January 9, 2014, the Internal Revenue Service (“IRS”) issued a revised version of previously released Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit...more

IRS Issues Long-Awaited Guidance Regarding the Allocation of Federal Rehabilitation Tax Credits

The Internal Revenue Service (“IRS”) recently issued guidance in Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit partnerships under IRC Sec. 704(b). The...more

Tax Court Ruling Impacts the Treatment of Income Allocations Attributable to Unvested Partnership Capital Interests

The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more

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