On October 17, 2023, the Internal Revenue Service (IRS) updated the electronic signature guidance in its Internal Revenue Manual (IRM) to reflect the electronic signature relief that the IRS provided to taxpayers during the...more
In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more
6/16/2023
/ Acquisitions ,
C-Corporation ,
Capital Gains ,
Federal Taxes ,
Gain Exclusion ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Mergers ,
Qualified Small Business Stock ,
Shareholders ,
Small Business ,
State Taxes ,
Tax Planning
One of the headline tax changes in the Inflation Reduction Act of 2022, Public Law 117-169, is a 1% excise tax on stock repurchases by public companies. New Section 4501 of the Internal Revenue Code applies a non-deductible...more
1/13/2023
/ De Minimus Doctrine ,
Dividends ,
Excise Tax ,
Fair Market Value ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
Leveraged Buyout ,
Liquidation ,
Loan buy-backs ,
Reorganizations ,
Stock Repurchases ,
U.S. Treasury
One of the headline tax changes in the Inflation Reduction Act of 2022, Public Law 117-169, is a 1% excise tax on stock repurchases by public companies. Public issuers should be aware that the new tax, which applies beginning...more
On Aug. 6, New York Attorney General Letitia James and D.C. Attorney General Karl Racine brought blockbuster lawsuits against the National Rifle Association and the National Rifle Association Foundation, alleging that these...more
As the COVID-19 pandemic spreads, the economy has struggled significantly under its new burdens. The impact both domestically and globally has been staggering, and many employers are interested in finding creative solutions...more
In our prior nonprofit alert, we reported that the Internal Revenue Service (the “IRS”) had not extended most federal tax payment and filing deadlines for exempt organizations. The IRS notices issued up to that point (Notice...more
The CARES Act (the Act) enacted on Friday, March 27, contains several provisions designed to provide relief for nonprofit organizations. In addition, a number of the provisions under the Act designed to help small businesses...more
Federal tax law changes enacted with the Tax Cuts and Jobs Act of 2017 may require tax-exempt organizations to reevaluate their compensation practices, particularly with respect to employee severance. Section 4960 of the...more
In a November 29, 2018 speech, Deputy Attorney General Rod Rosenstein announced a softening of the US Department of Justice’s (DOJ) policy on giving credit for cooperation in corporate prosecutions.
As memorialized in the...more
A new “centralized partnership audit regime” is now in effect for partnerships, including limited liability companies (LLCs) that are treated as partnerships for tax purposes (which we refer to collectively as...more
The Tax Act contains a number of provisions that significantly affect tax-exempt organizations, in some cases to degrees not seen in decades. In addition, several provisions may indirectly affect tax-exempts, for example, by...more
We previously reported to you that effective July 1, 2017, Massachusetts would require the collection of Massachusetts sales and use taxes by internet vendors that meet certain sales thresholds in Massachusetts pursuant to...more
The Massachusetts Department of Revenue (DOR) recently issued guidance under which it will require the collection of Massachusetts sales and use taxes by remote sellers that meet certain sales thresholds in Massachusetts....more