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The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
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PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
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With the holiday season officially upon us, the Dollars and Sense team wants to make sure you maximize your giving and gifting! For so many businesses, and business owners, this time of year also means employer festivities,...more
Good news! The second chamber (Bundesrat) has now paved the way for the eagerly awaited and much-debated inclusion of a group privilege in sec. 19a of the German Income Tax Act (“EStG”). German start-ups that have done the...more
Earlier this month, the IRS released Form 15620, a new standardized form for taxpayers seeking to make elections under Internal Revenue Code (“Code”) section 83(b). Previously, to make this election, taxpayers needed to...more
On November 20, 2024, Angola enacted Presidential Decree 8/24 on Oil & Gas Incremental Production (“Incremental Production Decree”). This legal statute creates a new special legal and tax framework aimed to promote additional...more
There are two recent taxpayer-friendly updates of note in the international tax filing arena. First, Internal Revenue Service (“IRS”) Commissioner Danny Werfel recently announced that the IRS is ending its automatic...more
On Nov. 15, the Federal Executive Branch presented the Economic Package for 2025 (“EP 2025”) to Congress, which estimates around 294 billion United States Dollars (“USD”) in tax revenue. The EP is a set of proposals,...more
As we approach the holiday season, many employers consider giving employees a gift as a token of appreciation. What employers may not consider is whether those gifts create taxable income to employees....more
Nota: El 15 de noviembre de 2024, el Ejecutivo Federal presentó ante la Cámara de Diputados el Paquete Económico para el 2025 (“PE 2025”), mismo que contempla 5.3 billones de pesos en ingresos tributarios. El paquete...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11, 2024 – November 15, 2024. November 11, 2024: The IRS released Internal Revenue Bulletin...more
This session of the Private Client West Coast Forum 2024 identified common types of privilege, highlighting potential pitfalls to avoid and tools to protect a client’s privileged information. Types of privilege include...more
This session of the Private Client West Cost Forum 2024 discussed best avenues for family offices and their advisors to consider when managing a complex post-death administration, including steps to address and anticipate...more
This session of the Private Client West Cost Forum 2024 explored the current state of audits and tax controversy and shared practical advice to prepare for challenges ahead of a contest with the IRS or Franchise Tax Board...more
This session of the Private Client West Coast Forum 2024 focused on recent developments, including income tax planning to support investment performance, executive compensation planning, private placement life insurance...more
Motor carriers and private fleet operators need to weigh several critical factors when deciding where to register and plate their motor vehicles and equipment (trailers, flatbeds, tanker units, etc.). Selecting the right...more
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
As 2024 quickly comes to a close, the new year will bring a change in the presidency, a new Congress, and potential changes to policies and laws that could impact individuals of all wealth levels. Going into the election,...more
The IRS Whistleblower Program helps boost the “fair and effective enforcement of our nation’s tax laws and the success of our voluntary tax system.” The IRS Whistleblower Program is dependent on people who become aware of tax...more
The January 1, 2025, compliance deadline for Corporate Transparency Act (CTA) filings for certain entities that were formed or registered to do business in the U.S. before 2024 is approaching quickly for many business owners....more
The re-election of former president Donald Trump as the 47th President of the United States will have major implications for the key policy issues described below. Empowered by a Republican majority in both chambers, though...more
This year was busy for trusts and estates practitioners. With 2025 marking the final year of the Tax Cuts and Jobs Act (TCJA), many of its implications for federal corporate and individual income tax, gift, estate and...more
On October 29, 2024, the Canada Revenue Agency (CRA) announced that bare trusts are once again exempt from filing the T3 Income Tax and Information Return (including Schedule 15 regarding beneficial ownership information of a...more
Internal Revenue Code Section 3405(e)(13) generally requires mandatory withholding on periodic and nonperiodic distributions that are to be delivered outside the United States unless the payee is a nonresident alien or recent...more
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more
December 2024 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The December Section 7520 rate for use in estate planning techniques such as CRTs, CLTs,...more
A new Alabama law clarifies the types of overtime wages exempt from state withholding, prompting the Alabama Department of Revenue to promulgate new rules. Last year, the Alabama Legislature enacted Act 2023-421,...more