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Internal Revenue Code (IRC)

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | April 2025

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Welcome back to the buzz, our monthly cannabis news and policy update. Your at-a-glance source for regulatory developments, agency announcements, and trends impacting the cannabis industry. In this edition of the buzz,...more

Allen Matkins

If You Agree That Stock Issuance Was Not "Compensation, Salary, Or Income", You May Want To Think Carefully Before Issuing A Form...

Allen Matkins on

Ten years ago, Hovik Nazaryan sued Femtometrix, Inc. claiming that the company had issued shares to him than it had promised.  The parties settled the lawsuit.  The settlement agreement provided that the stock issued to Mr....more

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

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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

Bressler, Amery & Ross, P.C.

How to Take Advantage of Changes in Interest Rates For Gift and Estate Tax Savings

A recent Tax Court order highlights the gift and estate planning opportunities afforded when a senior family member makes loans to other family members. In Galli v. Commissioner, Docket Nos. 7003-20 and 7005-20, the Court had...more

Frost Brown Todd

To Be Clear…LLCs Can Issue Qualified Small Business Stock (QSBS)

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Since the finalization of the IRS’s “check-the-box” entity-classification regulations nearly 30 years ago, a state law LLC can elect to be taxed an association taxable as a corporation. During the past month, we have heard...more

Foster Garvey PC

Hobby Loss Rules Revisited

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With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Goodwin

Recent Changes and Future Directions: Tax-Exempt Organizations Under the New Administration

Goodwin on

Executive orders, federal funding cuts, and suspended processing of tax-exempt status applications are among the changes affecting nonprofits. ...more

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

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Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Axinn, Veltrop & Harkrider LLP

Federal Circuit Holds Generic’s Hatch-Waxman Litigation Expenses Deductible

A March 21 Federal Circuit decision in Actavis Laboratories FL, Inc. v. United States, No. 23-1320 (Fed. Cir. Mar. 21, 2025) marked a victory for generic drug developers, affirming that legal expenses incurred defending...more

Winstead PC

The QPAM Exemption - Key Takeaways for Fund Managers with Benefit Plan Investors

Winstead PC on

As an asset manager, you may be familiar with the regulatory issues that come into play when a fund permits investments from “benefit plan investors,” which generally include certain employee benefit plans subject to the...more

WilmerHale

Section 1202: Qualified Small Business Stock

WilmerHale on

This article provides general information regarding U.S. federal income tax incentives available to non-corporate holders of “qualified small business stock” (“QSB stock”) as defined under Section 1202 of the Internal Revenue...more

Allen Matkins

The Possible Securities Act Implications Of Harvard's "Nyet" To Government Civil Rights Reform Demands

Allen Matkins on

Last week, the United States General Services Administration, Department of Education, and Department of Health and Human Services sent a letter to Alan M. Garber, the President of Harvard University, and Penny Pritzker, Lead...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Insider Transactions and Nonprofits

Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and this episode is a "refresh" of episode 32, recorded in March 2023. It covers the Internal Revenue Code sections pertinent to business...more

Dickinson Wright

ACA Reporting Update: Some Relief and Process Streamlining for Employers

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Applicable large employers (“ALEs”) are subject to reporting requirements under the Affordable Care Act (the “ACA”). To comply with the reporting requirements, an ALE must file a Form 1095-C with the IRS reporting certain...more

Womble Bond Dickinson

Micro-Captive Reportable Transaction Deadline Effectively Extended

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On Friday, April 11, 2025, the Internal Revenue Service issued Notice 2025-24 (the “Notice”), which waives applicable penalties under the Internal Revenue Code to participants in, and material advisors to, reportable...more

Eversheds Sutherland (US) LLP

Georgia’s 2025 legislative session: Tax legislation overview

During the 2025 legislative session, the Georgia General Assembly passed several notable tax related bills including further decreasing the income tax rate and extending the time period for taxpayers to protest and appeal the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Implementation of Section 45Z/Clean Fuels Production Credit: Energy Marketers of America Comments on Internal Revenue Service's...

The Energy Marketers of America (formerly, Petroleum Marketers Association of America) (“EMA”) submitted April 10th comments to the Internal Revenue Service (“IRS”) addressing its: …notice of intent to propose regulations...more

Holland & Knight LLP

The Tax and Trade Outlook from Washington, D.C., for Equine Businesses

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As Congress shifts into gear on the budget reconciliation process and tax day approaches, there are several key issues for horse owners to keep in mind. In the 119th Congress, there are two proposals that have been...more

Paul Hastings LLP

Crypto Tax Update – April 2025

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In light of the approaching April 15 tax filing deadline, this week’s update highlights recent developments in U.S. federal tax policy that may impact crypto firms and crypto holders....more

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

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Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Holland & Knight LLP

IRS Releases Form 4255 to Report Prevailing Wage and Apprenticeship Penalty Amounts

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The IRS recently released an updated Form 4255, Certain Credit Recapture, Excessive Payments, and Penalties, which is used to report the amount due for certain credit recaptures, excessive payments, excessive credit transfers...more

Ballard Spahr LLP

IRS Changes Course on Income Tax Impact of Employee Retention Credit

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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

Proskauer Rose LLP

Wealth Management Update - April 2025

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The April 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is 0.40% less than the March 2025 rate. The April applicable federal rate (“AFR”) for use with a...more

Proskauer - Employee Benefits & Executive...

A Trap for the Unwary – Nonprofit Organization Compensation Arrangement Considerations for High Caliber Executives

Like any for-profit company, nonprofit organizations want to attract and retain high caliber executives to achieve and further their missions. To accomplish this, a nonprofit organization may have to offer a particularly...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

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In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

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