Legal Principles of Fiscal Sponsorship for Sponsoring Organizations
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REFRESH Election Year Issues for Private Foundations and Public Charities: Legislative Lobbying Activities by Public Charities
Election Year 2026: A 501(c)(3) Compliance Refresher for Charities and Private Foundations
REFRESH Loot and an Introduction to Private Foundation Rules - Part 2
REFRESH Loot and an Introduction to Private Foundation Rules - Part 1
Childcare Benefits Under the Big Beautiful Bill: What's the Tea in L&E?
Tax Talk with Josh Wykle – The Big Beautiful Bill & Overtime Deductions: What's the Tea in L&E?
From Legislation to Implementation: Understanding Section 1202 Changes — Troutman Pepper Locke Podcast
Insider Transaction Traps for the Unwary
REFRESH Nonprofit Basics: Insider Transactions and Nonprofits
Nonprofit Basics: IRS 10-Course Charity Workshop
Nonprofit Basics: Unrelated Business Income Tax: Modifications and Exceptions - Part 2
Nonprofit Basics: Unrelated Business Income Tax: Basic Rules for Charities - Part 1
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy Rules for Public Charities
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Candidate Campaign Intervention
A recent federal court decision, Huang v. United States, offers important guidance for U.S. persons who have received large gifts from foreign persons, and failed to timely file Form 3520, Annual Return To Report Transactions...more
The intersection of tax and trade law has been in the news in recent months as businesses navigate changing tariff rules. We have written extensively about the cross-roads of tax law and tariffs. All this talk about tariffs...more
Welcome to the latest edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. We pull together the items we deem most important to provide...more
Much has been written about IRC Section 1202. Section 1202 affords non-C corporation taxpayers who sell a corporation’s qualified small business stock (“QSBS” or “1202 Stock”) issued after July 4, 2025 (and who satisfied the...more
On Thursday, April 23, 2026, the U.S. Department of Justice (DOJ) released its final order rescheduling certain marijuana products from Schedule I to Schedule III of the Controlled Substances Act (CSA). After publication in...more
The Trump administration is weighing whether to allow contributions of appreciated stock directly into §530A “Trump Accounts” — children’s savings accounts created by the One Big Beautiful Bill Act of 2025 (OBBBA), Pub. L....more
The IRS recently revised its FAQs (IRS FS-2026-10) addressing educational assistance programs under Internal Revenue Code Section 127. This updated guidance replaces the FAQs issued in June 2024 (IRS FS-2024-22) and reflects...more
Commercial real estate is in a sorting period. The Mortgage Bankers Association estimates roughly $5 trillion in commercial mortgages will mature between 2025 and 2029, with approximately $875 billion maturing in 2026 alone....more
The IRS Office of Chief Counsel issued Chief Counsel Advice 202618011, addressing whether a taxpayer can apply a revised cost allocation method under Treasury Regulation § 1.482-9 as a set-off in a transfer pricing context....more
Across the country, a quiet revolution is underway in unexpected places: church parking lots. From Los Angeles to Detroit, religious institutions of every denomination are sitting on some of the most underutilized land in...more
The IRS has taken oscillating positions on issuing corporate letter rulings on isolated issues in the context of a larger, integrated transaction. Since 2024, taxpayers have been required to request a letter ruling regarding...more
Have you switched providers and are now converting your retirement plan to a new form of preapproved plan document? Are you with the same provider but updating to a new preapproved plan document at the end of the six-year...more
Key Takeaways - The IRS announced it will soon release settlement terms for certain syndicated conservation and historic preservation easement disputes under Section 170(h)....more
What is a tax practitioner to do when they suspect—or worse, know— that their client committed tax fraud? In the first and second parts of this three-part series, we discussed the basic elements of civil tax fraud and...more
The Internal Revenue Service has released updated frequently asked questions addressing educational assistance programs under Section 127 of the Internal Revenue Code, along with a revised sample plan document, Publication...more
On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $2.4 billion deduction and imposed a 40%...more
On April 30, 2026, the Treasury and IRS released temporary regulations (T.D. 10047) and identical proposed regulations (REG-119294-25) under section 6435 of the Code, which was added by the One Big Beautiful Bill Act (OBBBA)....more
IRS final regulations clarify eligibility and reporting requirements starting in 2026...more
Most companies treat R&D Tax Credits the same way: something that happens to them at the end of the year, once the numbers are in and the accountant has done their work....more
In April 2026, the U.S. Department of Justice (DOJ) and Drug Enforcement Administration (DEA) announced a significant shift in federal cannabis policy. Effective immediately, the following categories of marijuana have been...more
IRS Rev. Proc. 2026-21, 2026-22 IRB 1, issued May 5, 2026, reinstates the Internal Revenue Service’s “significant issue” letter ruling program, under which the IRS will rule on specific, significant issues posed by a...more
For years, cannabis operators have functioned under a fundamentally distorted tax regime. Section 280E denied deductions that every other business takes for granted, forcing companies to pay tax on something closer to gross...more
With a federal estate tax rate of 40%, estate planning conversations often start and stop with the relatively high federal exemption (currently $15 million for individuals and $30 million for married couples). That can make...more
Following the Supreme Court of the United States’ decision invalidating most tariffs imposed under the International Emergency Economic Powers Act of 1977, many companies expect to receive tariff refunds with respect to...more
The IRS has reportedly begun the process of terminating a lead criminal investigation agent involved in probes of Malta pension structures and Puerto Rico’s Act 60 tax incentives, raising concerns about the continuity of...more