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
On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more
On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more
In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more
Business owners considering exit options from their businesses often can be blinded by purchase price figures and proceeds, often “accepting” that paying capital gains tax is part of the deal. The ability to avoid or defer...more
Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more
This third installment of my multi-part series on Subchapter S is focused on a single Code Section, namely IRC Section 1361(b)(1)(C) and the ineligibility of nonresident aliens as shareholders of Subchapter S corporations....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
On May 12, 2023, the Internal Revenue Service (IRS) published private letter ruling 202319013 (the PLR), which concluded that an enterprise cloud application software company is engaged in a qualified trade or business for...more
The Research and Development Tax Credit, formally known as the Credit for Increasing Research Activities under Section 41 of the Internal Revenue Code, has been in existence for many years to encourage companies to conduct...more
Earlier this year, the Internal Revenue Service (IRS) announced the creation of a new Joint Strategic Emerging Issues Team (JSEIT). The new initiative, announced at the New York University School of Professional Studies Tax...more
Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 24, 2022 – April 30, 2022... April 25, 2022: The IRS issued a news release, soliciting...more
In March 2010, Congress codified the economic substance doctrine in Internal Revenue Code (Code) Section 7701(o). The codification clarified that a conjunctive analysis applies in determining if the doctrine applies. The...more
On September 13, 2021, the Congressional House Ways and Means Committee introduced 880 plus pages of legislative tax proposals to help fund the House’s proposed $3.5 trillion stimulus package. Below are tax proposals relevant...more
In two recent cases, the IRS has tried to defeat research credit refund claims on procedural grounds, rather than simply litigating whether the substantive nature of the asserted research meets the requirements of section 41...more
With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 21 – December 26, 2020... December 21, 2020: The IRS released TD 9941 containing final...more
On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more
On November 18, the Internal Revenue Service and Treasury Department issued updated guidance on the tax deductibility of business expenses paid for with loan proceeds from the CARES Act Paycheck Protection Program (PPP). In...more
Under the CARES Act, PPP loans given to affected borrowers were potentially eligible for forgiveness without cancellation of indebtedness income. To qualify, an affected borrower must certify that (i) “the uncertainty of...more
Introducing Nossaman's Employment BUZZ webinar series! Each month, our attorneys will cover a different topic of interest to employers, including tax, insurance, intellectual property and employment issues. These "quick hit"...more
Episode #22 The Accidental Entrepreneur - The Optimal Corporate Set Up discusses the virtues and financial powers of creating your own business as a vehicle for ensuring your current and future financial stability. Consider...more
A central feature of the CARES Act, the Paycheck Protection Program (PPP), provided a lifeline to a multitude of small businesses during the early days of the Coronavirus pandemic. PPP loans were used to cover payroll...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 27, 2020 – July 31, 2020... July 28, 2020: The IRS issued final regulations providing...more