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
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
On September 8, 2023, Internal Revenue Service (IRS) Commissioner Danny Werfel announced the rollout of a coordinated enforcement strategy that will involve audits of returns filed by 75 of the largest partnerships operating...more
The Infrastructure Investment and Jobs Act (“IIJA”) has provisions to encourage investment in high-speed broadband projects, but as written, the legislation leaves open for interpretation several provisions. Guidance or...more
Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Scheider v. Comm’r, T.C. Memo. 2022-104 | October 11, 2022 | Urda, J. | Dkt. No. 4048-20 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 |...more
Tax Litigation: The Week of August 22nd, 2022, through August 26th, 2022 Warner Enterprises, Inc. v. Comm’r, T.C. Memo. 2022-85 | August 22, 2022 | Buch, J. | Dkt. No. 17163-19L. ...more
Tax Litigation: The Week of August 22nd, 2022, through August 26th, 2022 Alexander C. Deitch v. Comm’r, No. 21282-17; and Jonathan D. Barry and Susan S. Barry v. Comm’r, No. 21283-17, T.C. Memo 2022-86 | August 25, 2022 |...more
Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 | Panuthos, J. | Dkt. No. 1548-19S Soler v. Comm’r, T.C. Memo. 2022-78 | July 18, 2022 |...more
Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J. | Dkt. No. 13314-20. Genecure, LLC v. Comm’r, T.C. Memo 2022-52 | May 23, 2022 | Jones, J....more
The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) requires a public hearing as a form of public approval for certain types of tax-exempt private activity bonds. Thanks to COVID-19, holding a hearing is easier than...more
On March 18, 2022, the IRS issued Revenue Procedure 2022-20, which permanently allows issuers of tax-exempt private activity bonds to hold TEFRA hearings via teleconference. Pursuant to § 147(f) of the Internal Revenue...more
When dealing with the Internal Revenue Service during the initial stages of a tax case, whether it involves an audit, collection issue, request for penalty relief, or a proposed plan of resolution such as an Offer In...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
The Internal Revenue Service (IRS) has released Revenue Procedure 2021-39, which extends the time period for telephonic Tax Equity and Fiscal Responsibility Act (TEFRA) hearings until March 31, 2022. In response to the...more
On August 31, 2021, the IRS issued Revenue Procedure 2021-39, which allows issuers of tax-exempt private activity bonds to continue to hold TEFRA hearings via teleconference through March 31, 2022. Pursuant to § 147(f) of...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 31, 2020 – September 4, 2020. Additionally, for continuing updates on the tax impact of...more
On May 4, 2020 the Internal Revenue Service (IRS) released Notice 2020-21 (Public Hearing Notice) and Notice 2020-25 (Reissuance Notice). These Notices provide limited, temporary relief to issuers of tax-exempt bonds in two...more
TEMPORARY GUIDANCE REGARDING TEFRA HEARINGS - On May 4, 2020, effective immediately in response to the COVID-19 pandemic, the Treasury and the IRS issued Rev. Proc. 2020-21 that retroactively permits telephonic hearings...more
As a result of the prohibitions on public gatherings resulting from the COVID-19 pandemic, issuers of tax-exempt private activity bonds have been facing difficulty complying with the federal tax laws requiring that a public...more
The new centralized audit regime for partnerships established by the Bipartisan Budget Act of 2015 (“BBA”) has been in effect since January 1, 2018, but is your partnership or LLC treated as a partnership for tax purposes...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more
• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more
At the end of December, the Internal Revenue Service released the final regulations under Internal Revenue Code 147(f), which relate to public notice, hearing, and approval requirements for private activity bonds, which...more
On December 31, 2018, the Internal Revenue Service (“IRS”) published final regulations (the “Final Regulations”) regarding the public approval requirement for tax-exempt private activity bonds....more
In a very busy end of the year, the IRS provided two new bond regulations: The final public approval (TEFRA) regulations and proposed reissuance regulations....more