The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more
Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s ("DOJ") first criminal indictment related to syndicated conservation easements. Walter...more
A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. While generally donors who donate appreciated property to a public charity do not recognize...more
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’ if...more
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more
As the creation of and transactions involving non-fungible tokens (NFTs) have increased dramatically, so has interest in using NFTs as donations to charitable organizations and for other charitable fundraising tools. Given...more
Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more
The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more
OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...more
The Benefit of Knowing- Monday morning quarterbacking – the connotations are anything but positive. Life is full of instances in which someone, in possession of all the factors that informed – or that should have...more
On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more
On July 27, 2018, the Treasury issued final regulations regarding substantiation requirements for cash and noncash charitable contributions. T.D. 9836 (2018). The final Regulations reflect amendments to Section 170 of the...more
The Department of Justice has finally filed a civil complaint against certain promoters who have been spearheading syndicated easements to the tune of over $2 billion in claimed federal tax deductions using grossly inflated...more
In Exelon, the Seventh Circuit held that exchanges by Exelon Corporation (“Taxpayer”) of nuclear power plants for long-term leasehold interests in power plants located in other states were not exchanges qualifying for...more
Last month, the IRS issued final regulations entitled “Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions,” codified as Treasury Regulation Sections 1.170A-15 (cash), -16...more
May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more
As we enter the giving season and begin making charitable contributions it is important to remember that some gifts require more than just the act of giving to qualify for a charitable tax deduction. For monetary...more
We’ve all heard about India’s rape crisis, but not everyone knows that it’s the result of the larger problem of gender inequality. According to UNICEF, India is the worst place to be born a girl. The birth of a baby girl is...more
We have all been told at one point or another that we simply “can’t have it all.” But for owners of recreational or agricultural land who desire to preserve the land, pass it down to their descendants as a legacy property,...more
March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more
What’s a real estate developer to do when its pristine development site, with beautiful ocean views and room for between 164 and 410 upscale residential units that *NEED NOT BE BUILT, is clogged with wildlife, including bald...more
When planning their estates, most people focus on major assets, such as business interests, real estate, investments and retirement plans. But it’s also important to “sweat the small stuff” — tangible personal property. This...more
In Friedberg v. Comm’r, T.C. Memo 2011-238, the Tax Court granted summary judgment for the IRS, holding that an appraisal used to substantiate a facade easement donation amount was not a qualified appraisal because it...more