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
As investors increasingly leverage Section 1031 exchanges to defer capital gains taxes, nuanced scenarios involving interest income on exchange proceeds require careful analysis. A critical but often overlooked aspect arises...more
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
At a recent conference of the American Bar Association, Treasury Associate Tax Legislative Counsel Colin Campbell Jr. stated that the recent proposed regulations governing corporate spin-off and reorganization...more
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
Companies are increasingly allowing their chief executive officers and, in certain circumstances, other executives to use corporate jets (which may be chartered flights or fractionally or fully owned aircraft) for personal...more
The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more
Spinning the Globe: When the Music Stops, the IRS Listens - Imagine standing on stage in Ibiza, Tokyo, or Miami, spinning beats to millions while pulling in seven figures per gig. That’s the reality for Dutch DJs Tiësto...more
This Tax Alert is the second in a series of monthly alerts that I will issue to discuss tax legislation in 2025 and the outlook for the Inflation Reduction Act (IRA) renewable energy tax incentives. You can find the first Tax...more
On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more
The intersection of real estate transactions and tax strategy has long been a focal point for investors seeking to optimize returns while minimizing liabilities. Two powerful tools in this arena – the Membership Interest...more
In the years since COVID-19 shut down the country, many businesses applied for the Congressionally-authorized Employee Retention Credit (ERC), a valuable relief program created during the pandemic to support businesses who...more
Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...more
On April 17, the Internal Revenue Service issued a notice announcing its plans to withdraw a set of controversial regulations, finalized in January of this year, aimed at transactions designed to shift tax basis in...more
In recent years, the utilization of qualified small business stock (“QSBS”) under Section 1202 has grown considerably. Many businesses are formed as corporations at conception, private equity investors calculate the tax...more
The Tax Court recently held that a hedge fund’s basket option contracts were in substance tax ownership of the underlying basket securities. The hedge fund, through its affiliated entities, entered into 10 basket option...more
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...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
In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more
Mistakes happen, and the tax law can be complex and ambiguous. The question becomes, what does a taxpayer do if they discover a mistake on their tax return? Should an amended tax return be filed? In some cases, the taxpayer...more
Are you searching for information on how to choose the right tax attorney? Are you a U.S. taxpayer who has a challenge with the IRS or a state tax agency? Are you facing an IRS or state tax audit? Are you an American...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
As the April 15, 2025 deadline approaches, it’s essential to be prepared for filing your federal tax return. Whether you’re ready to submit your return or need more time, understanding the available options will help ensure a...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...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