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
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5, 2024 – August 9, 2024. August 5, 2024: The IRS released Internal Revenue Bulletin 2024-32,...more
On June 17, 2024, the Treasury Department launched “a new regulatory initiative to close a major tax loophole exploited by large, complex partnerships.”[1] The loophole: partnership basis-shifting transactions....more
On April 25, 2024, the US Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (T.D. 9993) (the “final regulations under section 6418”) concerning the election to transfer...more
On April 24, the Internal Revenue Service (IRS) issued final regulations (Final Regulations) regarding Section 897. In December 2022, the IRS issued proposed regulations under Sections 897 (the Proposed Regulations) and 892...more
How will the administration’s new crypto tax proposal affect your current digital strategy? How do recent price surges in many cryptocurrencies affect the taxable events of US taxpayers? The value of many...more
For the past 16 years, the U.S. Department of the Treasury’s Office of Tax Policy and the Internal Revenue Service’s joint Priority Guidance Plan has included the issuance of regulations relating to donor advised funds (DAFs)...more
On January 16, 2024, the Treasury Department and Internal Revenue Service (“IRS”) announced that the agencies are postponing the implementation of increased reporting requirements for digital asset transactions under the...more
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
On December 19, 2023, the U.S. Treasury Department (“Treasury”) announced the entry into force of the U.S.-Chile Income Tax Treaty (the “Treaty”). The Treaty provides for reduced withholding tax rates on income such as...more
The Internal Revenue Service (IRS) and US Treasury Department (Treasury) issued Notice 2023-80 (Notice) on December 11, 2023, addressing the extension of relief previously announced under the foreign tax credit rules, and...more
On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more
Over the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds (DAFs), which are accounts owned and controlled by public charities over which individual or...more
A strong stock market and “soft landing” have generated significant wealth this year. The gift tax, estate tax and generation-skipping transfer tax are all imposed on the fair market value of assets at the time of transfer....more
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more
A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more
The Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued guidance on June 14, 2023, regarding the Inflation Reduction Act's (IRA) two new clean energy tax credit delivery mechanisms – one on...more
In a recent article, we observed that the Treasury and the Internal Revenue Service (“IRS”) could address the complex tax issues presented by emerging digital assets either by developing a cohesive framework for taxing these...more
On Thursday, April 6, the Treasury Department and Internal Revenue Service (IRS) issued their long-term Strategic Operating Plan (SOP), outlining how the IRS intends to spend $79.4 billion in funding provided by the Inflation...more
Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more
On April 4, 2023, the Internal Revenue Service (IRS) released Notice 2023-29 (which follows an earlier notice [Notice 2022-51] released in October 2022 soliciting comments on bonus tax credit requirements) regarding certain...more
Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...more
On December 29, 2022, the US Treasury Department and the Internal Revenue Service (IRS) released guidance relating to the electric vehicle (EV) tax credit provisions of the Inflation Reduction Act of 2022, Public Law 117-169...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more
The Treasury Department and the Internal Revenue Service (IRS) released initial guidance on Dec. 27, 2022, concerning two corporate tax increases included in the climate and energy reconciliation bill commonly known as the...more
As previously discussed in our blog Inflation Reduction Act: Wage and Apprenticeship Requirements, the Inflation Reduction Act (the “IRA”) restructured the tax credit system associated with qualified clean energy projects...more