Navigating Contractor vs. Employee Classification
Insider Transaction Traps for the Unwary
Multijurisdictional Employers, Part 1: Independent Contractors vs. Employees
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
REFRESH Steps for Launching a New Charitable Corporation
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare
Nonprofit Basics: IRS 10-Course Charity Workshop
Nonprofit Basics: Unrelated Business Income Tax: Debt Financed Income - Part 3
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
Nonprofit Basics: Unrelated Business Income Tax: Modifications and Exceptions - Part 2
Navigating the Inflation Reduction Act: Insights on Brownfield Energy Community Credits - Energy Law Insights
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
REFRESH Nonprofit Basics: Year-End Thoughts and New Year To-Do List
What's the Best Transaction Structure for My Sale?
Year-End and Trending Tax Considerations for Health Care Practices
Nonprofit Basics: International Grantmaking – Part 2 Income Tax Withholding Rules
PODCAST: Williams Mullen's Benefits Companion - Tax Relief and Possible Retirement Plan Resources for Hurricane Victims
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
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025. IRS GUIDANCE - May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing...more
On May 14, 2025, the House Ways and Means Committee approved the “One, Big, Beautiful Bill,” containing the tax provisions destined for the budget reconciliation package. Several of the bill’s provisions would affect...more
It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
A March 21 Federal Circuit decision in Actavis Laboratories FL, Inc. v. United States, No. 23-1320 (Fed. Cir. Mar. 21, 2025) marked a victory for generic drug developers, affirming that legal expenses incurred defending...more
During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more
In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more
On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more
In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more
Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more
For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more
The “qualified small business stock” (QSBS) tax exemption under Section 1202 allows non-corporate founders and investors in certain emerging growth companies to potentially exclude up to 100 percent of the U.S. federal...more
Many non-US startup founders initially incorporate in their home country and then decide to reincorporate or create a subsidiary in the US. There are many advantages for foreign founders to move operations to the US,...more
Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more
Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
As it releases executive orders with unprecedented speed, the Trump administration has begun executing its vision for the United States and the world. This article addresses some of the tax-related topics likely to be the...more
On January 10, 2025, the United States Internal Revenue Service (the "IRS") released final regulations (the "Final Regulations") under section 6011 of the Internal Revenue Code of 1986, as amended (the "Code"), that identify...more
On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more
A common structure for equity REITs, the UPREIT model allows a REIT to hold and operate its assets through a single operating partnership. This structure provides tax advantages and liquidity opportunities for property...more
The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more
Did you know that you do not need to mail Form 1095-Cs if a notice is posted by March 3, 2025? At the end of last year, a new law was enacted that would allow employers to provide Form 1095-C only if requested, so long as the...more
The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more
On January 14, 2025, the Internal Revenue Service and the US Treasury Department issued proposed regulations under Section 162(m) of the Internal Revenue Code (Code) to implement changes under the American Rescue Plan Act of...more
Last week, speaking on Fox News, Commerce Secretary Howard Lutnick appeared to threaten the repeal of the exemption under Section 883 of the Internal Revenue Code for foreign corporations engaged in the international...more