Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more
AI in 2024: Monitoring New Regulation and Staying in Compliance With Existing Laws Companies that develop or employ AI tools have to consider proposed AI-specific regulation as well as an array of existing IP, privacy,...more
12/22/2023
/ Acquisitions ,
Artificial Intelligence ,
CFIUS ,
China ,
Cybersecurity ,
Data Privacy ,
Energy Sector ,
EU ,
Intellectual Property Litigation ,
Intellectual Property Protection ,
International Litigation ,
Investment ,
IRS ,
Mergers ,
National Security ,
New Hires ,
New Legislation ,
New Regulations ,
Outer Space ,
Private Equity ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Taxation ,
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UK
New Funding, New Focus -
With some $80 billion in initial funding from the Inflation Reduction Act (IRA), the Internal Revenue Service (IRS) began ramping up taxpayer services, issue resolution planning, compliance and...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
9/13/2023
/ Enforcement Actions ,
Estate Planning ,
Inflation Reduction Act (IRA) ,
Investment Management ,
IRS ,
Offshore Funds ,
Partnerships ,
Private Equity ,
TEFRA ,
Trustees ,
Wealth Tax
In the new episode of our tax podcast, “GILTI Conscience,” Fred Goldberg shares insights from his illustrious five-decade career in tax law, from his time as a junior associate through his service as the commissioner of the...more
Corporations have a long tradition of community engagement through corporate responsibility programs that have customarily involved attention to diversity and inclusion, environmental sustainability, and charitable giving or...more
The Internal Revenue Service (IRS) recently issued an alert regarding a phishing email scheme in which cybercriminals pose as governmental officials or company executives and request employee payroll and tax data, including...more
This afternoon, Reps. Kevin Brady (R-Texas) and Joseph Crowley (D-N.Y.) re-introduced in the House of Representatives a bill to significantly reform the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R....more
On May 9, 2014, the U.S. Department of the Treasury (Treasury) released proposed regulations defining the term “real property” for purposes of the REIT rules. The proposed regulations, which provide a framework for taxpayers,...more
The Non-Profit Revitalization Act of 2013 (the Act) (S5845/A8072), which effects the first major overhaul of the New York Not-for-Profit Corporation Law (the NPCL) in four decades, will be signed into law by New York Governor...more
On November 14, the IRS contacted many firms to let them know that the so-called REIT working group has completed its task. The IRS’s temporary hold on issuing rulings on what constitutes real property for REIT purposes is...more
The IRS Appeals Division (Appeals) recently released interim guidance for all its officers with respect to the handling of issues raised in Appeals but not challenged during the IRS Examination Division’s (Exam) consideration...more
Yesterday, Reps. Kevin Brady of Texas and Joseph Crowley of New York proposed a major reform to the Foreign Investment in Real Property Tax Act (FIRPTA). Introduced as H.R. 2870, the Real Estate Investment and Jobs Act of...more
A significant amount of press attention has been given to an unusual press release filed with the SEC yesterday by Iron Mountain regarding its planned conversion to a real estate investment trust (REIT). Iron Mountain said...more
IRS Addresses Issues of Unrelated Business Taxable Income and Executive Compensation in Colleges and Universities Compliance Project Report -
On April 25, 2013, the Internal Revenue Service (IRS) released its Final...more
Penn National Gaming, Inc. (PNG) announced last evening the first-ever tax-free spin-off of a “PropCo” real estate investment trust (REIT) from a taxable C corporation. PNG intends to separate its real property gaming...more
11/16/2012