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
Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more
Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more
The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...more
In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more
¿Qué sucede si un agente de retención de los EE. UU. de una institución financiera extranjera (FFI) aplica erróneamente una retención del capítulo 4 de FATCA del Código de Rentas Internas (IRC) del 30% a un pago a la FFI?...more
What if a U.S. Withholding Agent of a Foreign financial Institution (FFI) erroneously applies a 30% Internal Revenue Code (IRC) Chapter 4 FATCA Withholding to a payment to the FFI? What can be done to recover the funds? ...more
Little is written regarding FATCA and U.S. Financial Institutions (FI). That said, U.S. FIs have FATCA responsibilities. In the absence of permitted exceptions, FATCA requires U.S. FIs that make payments of most types of...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 20 – 24, 2020. January 20, 2020: The IRS released new Instructions to IRS Form 1120-S, US...more
The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more
The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more
The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more
The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more
On September 18, 2015, the Internal Revenue Service (IRS) issued Notice 2015-66, in which Treasury and the IRS announced that they intend to extend certain transition rules and modify certain other reporting rules under the...more
Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more
Notice 2013-43 (http://www.irs.gov/pub/irs-drop/n-13-43.pdf), released on July 12, 2013, announces the Internal Revenue Service's (the "IRS") and the Department of the Treasury's intent to amend final Treasury regulations...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more