Nonprofit Basics: International Grant Making - Part 1 Overview and Antiterrorism Rules
Top Gun: Maverick - Core Estate Plan and Gifting Basics
US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
How Tax Works - Entity Selection
TRAs: Benefits, Complexities (and Private Jets) Explained with Tax Attorney David Peck
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
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Once Removed Episode 19: The Step-Transaction Doctrine and the Case of Smaldino
Digital Planning Podcast Episode: Planning for Influencers
Once Removed Episode 18: The Reciprocal Trust Doctrine
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
Charitable Planning With Guest Stephanie Hood: Navigating Complex Rules and Traps for the Unwary
The Presumption of Innocence Podcast: Episode 28 - Under the Microscope: Examining the Future of the ERC
Once Removed Episode 16: Gift and Estate Tax, Inflation Adjustments for 2024
Once Removed Episode 17: Annual Gifting to Individuals: Options, Opportunities and Pitfalls
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
On September 12, 2024, the U.S. Department of Justice (“DOJ”) announced that Frank Richard Ahlgren III pleaded guilty to filing a false tax return underreporting gains from selling $3.7 million in Bitcoin. As we discussed...more
Americans who live abroad continue to be subject to U.S. taxation despite having left the United States. American expats should be aware of this and the consequences of not being tax compliant. George McCormick discusses...more
Kilpatrick’s David Hughes recently participated in a panel discussion at the Taxpayers’ Federation of Illinois annual state and local tax conference in Rolling Meadows, Illinois. David’s session, “Income Tax Jeopardy! A...more
In a recent news release (available here), the Internal Revenue Service (“IRS”) warned taxpayers about promoters claiming their services are needed to resolve unpaid taxes owed to the IRS....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23, 2024 – September 27, 2024....more
A number of Connecticut municipalities listed below are scheduled to conduct real property revaluations effective October 1, 2024. ...more
New York State Governor Kathy Hochul signed NYS Senate Bill 8647 (Martins)/Assembly Bill 10355 (Stern) into law this week....more
In Barclays Service Corporation and another v HMRC, the First Tier Tribunal (the “FTT”) has held that the UK branch of an overseas company did not qualify as a member of a value added tax (“VAT”) group in the UK....more
The outcome of the upcoming elections is likely to significantly impact future tax legislation. Notably, many tax provisions enacted under prior tax legislation, commonly called the Tax Cuts and Jobs Act (the “TCJA”), will...more
On this episode of “Splitting Heirs,” Warren K. Racusin welcomes back Sharon L. Klein, President of Family Wealth for the Eastern US Region of Wilmington Trust Company and member of the Estate Planning Hall of Fame, to...more
Three and a half days after it convened, the Colorado Legislature ended its special session on property tax. The session was called in response to a dramatic increase in property taxes that both residential and commercial...more
On June 25, 2024, Congressman Matt Gaetz (R-FL) introduced H.R. 8822 (the “Bill”), which would add Section 6316A to the Code, allowing individuals to pay their federal income tax using Bitcoin. According to Gaetz, “enabling...more
For California property owners that could potentially reduce their property taxes with a decline-in-value assessment appeal, the property tax assessment appeals for 2024 are due by either September 16 or December 2 depending...more
Introduction - In this revenue ruling, the Service addressed the application of the economic substance doctrine to certain basis-shifting transactions which result from the operative rules of Subchapter K. Generally, the...more
Kilpatrick’s Samantha Breslow, Jordan Goodman, David Hughes, and Jeffrey Reed presented “Discussion of State Tax Cases, Issues & Policy Matters to Watch” and “Where’s Waldo? Sales Sourcing in Today’s SALT World” during the...more
The 2024 Paris Olympics are in full swing, and it is never too early for U.S. athletes to consult with their tax advisor. As was done in 2021, the United States Olympic & Paralympic Committee has pledged to award U.S....more
In a February Legal Update, we analyzed the Taxpayer Protection and Government Accountability Act (the “Taxpayer Protection Act” or the “Act”), a statewide California ballot initiative that could potentially repeal the...more
Centralized Partnership Audit Regime (CPAR) is a somewhat new regime that followed TEFRA. Congress promulgated CPAR as part of the Bi-partisan Budget Act of 2015. For taxable years beginning in 2018, CPAR is the controlling...more
On June 28, 2024, the Treasury and the IRS released final regulations on reporting requirements for brokers of digital assets (the “Final Regulations”) and provided transitional relief, including Notice 2024-56, Notice...more
Oftentimes companies are on the defense in establishing that they are not operating a unitary business to avoid excessive taxation by a State. Yet, there are occasions when companies take the offense—and are successful. In...more
In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more
State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more
On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more
During the 2024 regular session of the Connecticut General Assembly, seven bills were passed and signed into law that deal with a variety of property tax matters. Of these, the most significant is Public Act No. 24-151. This...more
A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more