Freeman Law

In Varian Medical Systems, Inc. v. Commissioner, the Tax Court addressed a seeming oversight in the Tax Cuts and Jobs Act of 2017 (the “TCJA”) involving the effective dates for amendments to section 78 and the enactment of…more

Controlled Foreign Corporations, Dividends, Internal Revenue Code (IRC), Tax Court, Tax Credits

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Jason Freeman

Insider Trading Law | An Evolving Landscape

Throughout the history of the U.S. stock market, individuals have used insider access to information to gain an unfair advantage over other investors. The use of material non-public information (“MNPI”) in financial trading by…more

Enforcement Actions, Illegal Tipping, Insider Trading, Material Nonpublic Information, Personal Benefit

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Cory Halliburton

DOL Final Rule on Exempt Employee Salary Thresholds

On July 1, 2024, the Department of Labor’s final rule on exempt employee compensation thresholds went into effect. Each of the regulations sections 541.100 (executive employee), .200 (administrative employee), and .300…more

Department of Labor (DOL), Exempt-Employees, Fair Labor Standards Act (FLSA), Final Rules, Highly Compensated Employees

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Jason Hendrix

Texas Franchise Tax Basics | Nexus

If you own a business in Texas, you’ve likely encountered (for better or worse) the Texas franchise tax. The franchise tax is a tax imposed on any “taxable entity” that does business in Texas or that is chartered or organized…more

Franchise Taxes, Franchises, Franchisors, Income Taxes, State Taxes

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Fernando Juarez

The Cautionary Tale of the Malta Pension Plan: First, Civil Audits, Now Criminal Investigations

Few things scare a taxpayer more than the IRS knocking on their door. But when the taxpayer realizes that the person knocking on the door is a Special Agent of the Criminal Investigation Division (“CID”) of the IRS, well……more

Criminal Investigations, Employee Benefits, IRS, Pensions

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Clay McMillan

Reviewing Rev. Rul. 2024-14 | Partnership Basis-shifting Transactions, and the Economic Substance Doctrine

Introduction - In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally, the…more

Income Taxes, Tax Liability, Tax Planning

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Micah Miller

Agreeing to Make Arbitral Decisions Subject to Appeal

Decisions rendered in an arbitration proceeding are usually final, meaning they are not appealable. Frequently, this is highlighted as one of arbitration’s advantages. Many—if not most—agreements to arbitrate expressly declare…more

Arbitration, Arbitration Agreements, Arbitration Awards, Federal Arbitration Act

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Andrew Mirisis

IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain

PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions - Introduction to Section 961 and Mid-Year Distributions - For years, there has been a longstanding question under the subpart F rules…more

Controlled Foreign Corporations, Corporate Taxes, Income Taxes, Internal Revenue Code (IRC), IRS

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Gregory (Greg) Mitchell

When is an Issue Tried by Consent?

In a recent trial, I had occasion to encounter the issue of when an issue can be considered to have been tried by consent. The trial was an adversary proceeding in a bankruptcy court, and the issues related to the alleged…more

Bankruptcy Court, Creditors, Debtors, Evidence

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Matthew Roberts

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations for…more

Failure-to-File, Income Taxes, Internal Revenue Code (IRC), IRS, Lack of Authority

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Stephanie Uribe

Propuesta de Reglamentación para Fideicomisos Extranjeros Análisis de la Sección 643(i) del IRC

El 8 de mayo de 2024, la Secretaría de Hacienda de los Estados Unidos (“Treasury Department”) dio a conocer propuestas de reglamentos que abordan la clasificación, tributación y requisitos de información para fideicomisos…more

Foreign Trusts, Internal Revenue Code (IRC), Ministry of Finance, Reporting Requirements, U.S. Treasury

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Cindy Wofford

Another IRS Adverse Private Letter Ruling | Revocation of Tax-Exempt Status and Organizational and Operational Issues

In this ruling, a corporation’s I.R.C. § 501(c)(3) tax exempt status was under scrutiny. The corporation (“Company”) represented in its articles of incorporation and during its Form 1023 application process that it was organized…more

501(c)(3), Charitable Organizations, Filing Requirements, Form 990, Internal Revenue Code (IRC)

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Freeman Law

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