Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
Podcast - La Prima por Fusión
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
10 Things Lawyers Should Know About BVI Transactions
Tax Planning Under a Biden Presidency
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Tax Provisions in Business Acquisition Agreements
McDermott’s Family Office Symposium 2024 gathered more than 275 family office executives to explore creative solutions to navigate complexity and gain fresh perspectives on the challenges they face. Over two days,...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12, 2024 – August 16, 2024. ...more
This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
I mentioned my year long writing sabbatical last week. Over the course of the year, I have accumulated a few ideas to cover in new articles. One of those ideas is threading the needle of tax-exempt organizations with...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more
The Tax Cuts and Jobs Act (TCJA), which became effective on January 1, 2018, made significant changes to tax legislation that impacted individuals, families, business owners and companies. Some changes were intended to be...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
What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more
El IRS se centra en las empresas desde la aprobación de la Ley de Reducción de la Inflación. Según el Plan Operativo Estratégico (financiado por la Ley de Reducción de la Inflación), el IRS está aumentando las tasas de...more
IRS is focused on Businesses since the passage of the Inflation Reduction Act. Under the Strategic Operating Plan (funded by the Inflation Reduction Act), the IRS is increasing audit rates, expanding enforcement and targeting...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 24, 2024 – June 28, 2024. ...more
While marijuana advocates celebrate the potential rescheduling of marijuana from Schedule I to Schedule III, the taxman has made clear that marijuana remains a Schedule I substance subject to Section 280E of the Internal...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10, 2024 – June 14, 2024....more
On June 21, 2024, the Internal Revenue Service (IRS) released an early draft of revised Form 6765, Credit for Increasing Research Activities. Following the release of the September 2023 draft Form 6765 which dramatically...more
In Leto v. United States, the taxpayer reincorporated an S corporation business into a C corporation, then the taxpayer later sold the shares in the C corporation and tried to exclude the gain from such sale under section...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024. ...more
The various forms of information reporting required by the Internal Revenue Code form the backbone of both voluntary compliance with tax laws and the starting point for audits by the Internal Revenue Service (IRS). One form...more
On February 21, 2024, the IRS announced plans to increase funding under the Inflation Reduction Act to audit the use of corporate aircraft by large corporations, partnerships, and high-income individuals....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 11, 2024 – March 15, 2024. ...more
The Employee Retention Credit (ERC)—sometimes called the Employee Retention Tax Credit or ERTC—is a refundable tax credit for certain eligible businesses and tax-exempt organizations that had employees and were affected...more
On March 5, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued a notice of proposed rulemaking (the Proposed Regulations) and final regulations (the Final Regulations) regarding...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4, 2024 – March 8, 2024. ...more
Earlier today, the White House released its fiscal year (FY) 2025 budget request to Congress. Overall, it proposes $7.3 trillion in total spending, including a proposed $895 billion for defense and approximately $621 billion...more
Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more
This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more