Bar Exam Toolbox Podcast Episode 269: Listen and Learn -- Creation of Partnerships
An Alternative to Consolidations: Key Considerations for Management Services Organizations
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Into the Future: Modern Partnerships in Health Care Construction Delivery
NGE On Demand: Profits Interests: Granting & Receiving with Patty Cain and Josh Klein
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Sitting with the C-Suite: Managing the Merger and Looking Toward the Future
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Sitting with the C-Suite: AI as the Future of eDiscovery
Sitting with the C-Suite: Reveal's Acquisition of NexLP – Making Bold Moves by Leading with AI
Episode 021: Member Liquidity, Default Rules, and the Corporate-ization of LLCs: A Conversation with Dean Donald J. Weidner
Assessing the PE Partner’s Experience, Financial Track Record, and Culture: Critical Consideration #5 - Thought Leaders in Health Law Video Series
Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
Roetzel HealthLaw HotSpot: Optimizing Your Practice for Sale
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
[WEBINAR] Laying the Foundation for Maximizing Benefits Around Emerging Technologies
On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more
The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more
Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
On February 21, 2024, the Internal Revenue Service (IRS) announced a new initiative to audit the use of airplanes by corporations, large partnerships and high-net-worth individuals. While the IRS has always examined plane...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to conduct dozens of audits on the use of business aircraft by large corporations, partnerships, and high-income individuals as part of its “campaign”...more
Few individual owners of a closely held business would be surprised if you explained to them that the IRS and the Federal courts generally will subject many transactions between certain “related” persons to heightened...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more
El 20/09/23, el IRS anunció que planea establecer un área especial para centrarse en entidades de transferencia grandes o complejas para ayudar con los esfuerzos de cumplimiento de altos ingresos. Con la ayuda de tecnología...more
On 9/20/23, the IRS announced that it plans to establish a special area to focus on large or complex pass-through entities to help with high-income compliance efforts. With the assistance of improved technology as well as...more
En 9/8/23, el IRS anunció nuevos esfuerzos de cumplimiento que se centrarán en aumentar el escrutinio de los contribuyentes de altos ingresos/altos patrimonios, sociedades, corporaciones y promotores que abusan de las normas...more
The Internal Revenue Service plans to deploy thousands of new hires to expand audits of partnerships and high net wealth individuals. As part of a larger transformation at the agency, it is using some of the $60 billion in...more
On 9/823, the IRS announced new compliance efforts that will focus on increasing scrutiny on high-income taxpayers, partnerships, corporations and promoters abusing tax rules on the books by using Artificial Intelligence and...more
New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules. The IRS has formally given notice that it intends to...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more
The Internal Revenue Service (IRS) recently announced a renewed effort to ensure compliance with federal tax law, specifically focusing on high-income earners, partnerships, and large corporations. This additional scrutiny...more
Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large...more
The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more
With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules. Under these rules, the default is that the...more