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
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
On March 25, 2024, the IRS issued proposed regulations (REG-108761-22) which, if finalized, would identify certain CRATs as listed transactions. For those unaware of the listed transaction rules, such a designation would...more
On March 1, 2022, the IRS published its 129-page Exempt Organizations Technical Guide TG 62 Excise Taxes on Taxable Expenditures. While not authoritative or controlling, the guidance addresses in great detail the definitions...more
On January 19, 2021 the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) published in the Federal Register Final Regulations (the “Final Regulations”) interpreting the excise tax under Section...more
The Treasury Department (the “Department”) and Internal Revenue Service (“IRS”) recently released detailed proposed rules (the “Proposed Regulations”) interpreting Section 4960 of the Internal Revenue Code (the “Code”). 85...more
The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of...more
Seyfarth Synopsis: The IRS recently issued proposed regulations providing guidance under Internal Revenue Code (“Code”) Section 4960, which provides for an excise tax on tax-exempt organizations that pay certain executives in...more
The Internal Revenue Service has issued proposed regulations describing the rules regarding the 21 percent excise tax on compensation over $1 million and excess parachute payments paid by tax-exempt organizations to certain...more
Good news to close out the year: The “Further Consolidated Appropriations Act, 2020” (H.R. 1865 - the “2020 Act”) retroactively repeals the much maligned tax on qualified transportation fringe benefits (the so-called “church...more
As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more
• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...more
In the past decade or so, the competition for executive talent in the tax-exempt sector of the United States economy has increased. Executives seldom begin and end their careers with the same organization and there is...more
All entities, including governmental entities, are now potentially liable for penalties due to overpaying employees....more
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
Although much of the reporting on the Tax Cut and Jobs Act recently enacted by Congress has focused on the deductions for individuals and businesses, the bill also includes several provisions that apply specifically to...more
Over the past decade, the Healthcare Industry has been accustom to being center stage in political debates, but while medical providers and facilities did not have a prominent role in the latest political drama, the far...more
Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax...more
The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more