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
On August 19, 2024, the Internal Revenue Service (IRS) and the Department of the Treasury (Treasury) issued proposed regulations (Proposed Regulations) making changes to previously proposed regulations published in December...more
What is a hedged executory contract? A “hedged executory contract” is another type of transaction that is eligible for integration under Code Section 988(d). A hedged executory contract results when a taxpayer enters into an...more
Are there special hedging provisions for section 988 transactions? Yes. In addition to the business hedging rules I address in our earlier Q&A with Andie series, a special hedging provision is available at Code section 988(d)...more
Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 22, 2022 – August 26, 2022....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more
This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more
The IRS has published Proposed Regulations clarifying that for purposes of the mark-to-market rules under section 1256, foreign currency contracts include only foreign currency forward contracts, and that the definition does...more
Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more
A sovereign nation’s decision to adopt Bitcoin as legal tender raises interesting questions — and legal ramifications. On June 8, 2021, El Salvador’s Legislative Assembly voted to establish Bitcoin as unrestricted legal...more
Electric truck-maker Lordstown (that “aimed to revive a shuttered General Motors factory in Ohio”) revealed this week in a regulatory filing that it does “not have enough cash to start commercial production of its electric...more
Last Saturday, El Salvador’s President Nayib Bukele announced he was proposing bill that recognizes Bitcoin as “legal tender.” If enacted, El Salvador will become the first sovereign nation to formally recognize Bitcoin as...more
On April 9, 2021, the Internal Revenue Service (Service) released Chief Counsel Advice 202114020 (the Guidance) regarding the tax consequences to an individual in receipt of Bitcoin Cash (BCH) following the August 2017 hard...more
Technology seems to be advancing faster than we can keep up. These advances impact the employer community as well—even regarding basic things such as how, when, and in what manner wages are paid. Take two recent examples...more
It answers some questions but leaves many issues unresolved. On December 29, the US Internal Revenue Service (IRS) issued Notice 2018-07—Guidance under Section 965 (the Notice)—indicating its intent to issue regulations...more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more
The U.S. Department of the Treasury announced on July 7, 2017, in Notice 2017-38 (the Notice) that it has identified as "significant tax regulations" eight sets of U.S. federal tax regulations that were issued between Jan. 1,...more
Recently, in Wright v. Commissioner, the United States Court of Appeals for the Sixth Circuit has reopened the question of the application of Section 1256 to foreign currency options (and also, possibly, to foreign currency...more
IRS PROVIDES RICS ALTERNATIVES TO ACCOUNT FOR FOREIGN TAX REFUNDS - Generally, when a U.S. taxpayer pays foreign tax, the U.S. taxpayer is entitled to take a credit (a “Foreign Tax Credit”) against the taxpayer’s U.S....more
In This Issue: - Distinguishing Between Captive Insurance and Related Party Derivatives: Chief Counsel Advice Memorandum 201511021 - Achieving Tax-Free ‘Rollover’ Treatment for Certain Shareholders in Acquisition of...more
Because Bitcoin is fungible and greatly fluctuates in value on a daily basis, Bitcoin users will need to track their cost basis for each Bitcoin obtained and determine whether they have gain or loss on the subsequent exchange...more
There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more
On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more