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
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
An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more
[Editor’s Note: This article has been republished with permission. It was originally published December 20, 2023 on the eDiscovery Assistant Blog] In Episode 127, on the ACEDS and eDiscovery Assistant #CaseoftheWeek, Kelly...more
Recently, in a criminal case involving a physician who hired an accountant to prepare and submit certain tax forms to the IRS on her behalf, the court denied attorney-client and work-product privilege claims and ordered the...more
...A communication must be made for the purpose of legal advice to be protected from disclosure by the attorney-client privilege. If legal advice is not the purpose of the communication, the attorney-client privilege does not...more
The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more
The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Cynthia L. Hackerott. In today’s edition,...more
Last week, the Internal Revenue Service issued a polite notice (IR-2021-186) to employers and tax practitioners, as part of National Small Business Week, “to remind… business owners to correctly identify workers as employees...more
Kovel Agreement - The Internal Revenue Service (IRS) has broad statutory authority to investigate and audit taxpayers. In many cases, the IRS attempts to fulfill this statutory authority through seeking communications made...more
Lawyers, tax or otherwise, understand that privileged information must be protected to encourage a full and frank dialogue that might not occur without confidentiality.1 Tax information, in particular, contains some of the...more
Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more
The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more
In many respects, operating a law firm is no different than any other business. Specifically, the law firm generates revenues through providing services to its clients and incurs various operating expenses throughout the...more
This Holland & Knight alert is not focused on the structured trust advantaged repackaged securities (STARS) transaction or the economic substance doctrine, which were the primary issues before the U.S. Court of Appeals for...more
In Taylor Lohmeyer Law Firm P.L.L.C. v. United States, No. 19-50506, 2020 WL 1966844 (5th Cir. Apr. 24, 2020), the United States Court of Appeals for the Fifth Circuit held that a Texas-based estate and tax-planning law firm...more
In Taylor Lohmeyer Law Firm P.L.L.C. v. United States, No. 19-50506, the United States Court of Appeals for the Fifth Circuit held that a Texas-based estate and tax-planning law firm (Firm) could not invoke the...more
A recent decision of the U.S. Court of Appeals for the Fourth Circuit (one among the 13 appeals courts of the U.S. federal court system) underscores the importance of the attorney-client privilege. In a case titled In re:...more
An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege. That said, according to the Internal...more
Court rules that a "John Doe" summons to obtain confidential client records from a law firm isn’t barred by attorney-client privilege. On May 15, 2019, a district court in the Western District of Texas held that the...more
The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek...more
This video is the first in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage one - planning for and handling the IRS examination. He emphasizes the importance of...more
Executive Compensation Recoupment - The most recent development in the prominent University of Louisville Foundation controversy is the release of an independent analysis suggesting that its senior executive leadership was...more
June Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-family Loans and Split Interest Charitable Trusts - The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more
The Nonprofit Organizations Practice at Pillsbury has prepared this summary of significant legal and policy developments that have occurred in approximately the past year. All of these developments have potential impacts upon...more
October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more