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
For an active business in the post-Tax Cuts and Jobs Act (TCJA) world of lower corporate tax rates, buyers and shareholders considering a future exit should always consider C corporations and the availability of potential...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
Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
The Internal Revenue Service has announced the new limits for the Gift and Estate Tax Exemption for 2024, the amount of taxable gifts that can be made during lifetime and/or the amount that can be passed at death without...more
The Tax Court recently ruled that a limited partner’s share of business income may be earnings from self-employment. Earnings from self-employment are subject to the self-employment tax. Earnings from self-employment...more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
The IRS recently released its inflation adjustments for 2024. International private client practitioners should note the following: US Estate and Gift Tax Exclusion Amount: $13,610,000 (up from $12,920,000)...more
Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more
The IRS has announced the official estate and gift exclusion amounts for 2023. For an estate of any decedent dying during calendar year 2023, the applicable exclusion is increased from $12.06 million to $12.92...more
The basic exclusion amount is the total amount that an individual may pass by gifts made during his or her lifetime or by devises and bequests at his or her death without liability for federal estate, gift or generation...more
The year-end is approaching, but you still have time to work on your 2022 tax planning. Consider giving to your favorite charity to make this holiday season merry. Planned charitable giving provides you a way to maximize...more
I have yet to meet a client who wants to pay estate taxes. Tax avoidance is among the primary reasons people meet with estate planning attorneys and develop estate plans. In 2022, the federal gift, estate, and generation...more
The IRS released Revenue Procedure 2021-45 which announces the increase in 2022 of the estate, gift and generation-skipping transfer tax applicable exclusion amounts from $11.7 million to $12.06 million. The applicable...more
The Internal Revenue Service recently issued Revenue Procedure 2021-45 providing calendar year 2022 inflation adjustments for more than sixty tax provisions. Two of these adjustments are of particular interest to estate...more
If you are in the holiday spirit this season, you may wish to make gifts using the 2021 annual federal gift tax exclusion amount. To qualify for this exclusion for the year 2021, the gifts must be made no later than December...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 22, 2021 – February 26, 2021... February 25, 2021: The IRS issued an alert warning...more
An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue...more
On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more
Section 199A of the Internal Revenue Code, introduced by the Tax Cuts and Jobs Act (“TCJA”), created an opportunity for business owners to substantially lower their income taxes. Subject to many qualifications, beginning in...more
It's time to start the conversation with your tax advisor. The 2019 filing deadline is Monday, April 15. Note the new tax brackets. The new law imposes a new tax rate structure with seven tax brackets for 2018: 10%, 12%, 22%,...more
In Notice 2018-95, released on December 4, 2018, the Internal Revenue Service (IRS) formally announced a “once-in-always-in” interpretation of the section 403(b) participation exclusion for part-time employees and provided...more
On November 23, 2018, the Internal Revenue Service (“IRS”) proposed new regulations that prevent individuals who make a gift of more than $5,000,000 before 2026 from being double taxed on those gifts if they die after 2026.1...more
Federal Transfer Taxes - The Internal Revenue Service has announced the annual inflation adjustments for the 2019 tax year... Federal unified gift and estate tax exclusion increasing to $11,400,000: As of January 1,...more
When the 2017 Tax Cuts and Jobs Act was passed, significant changes were made to the Federal Estate, Gift and Generation-Skipping Transfer Tax, the most prominent of which is the increased applicable exclusion amount, which...more