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
Earlier this month, the IRS released Revenue Procedure 2024-24, which sets forth new requirements for requests for private letter rulings ("PLRs") on corporate spin-off and split-off transactions. (Both spin-offs...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
Despite ultimately finding in favor of a taxpayer surviving spouse, IRS Private Letter Ruling 2023-22-014 (the “PLR”) is chock-full of reasons to ensure proper planning is in place when it comes to IRAs....more
Private Letter Ruling 202244002, November 4, 2022 - In a recent Private Letter Ruling, the Internal Revenue Service granted a partnership 120 days from the date of the letter to make an election under §754 of the Internal...more
Taxpayers routinely resolve their tax controversy matters without resort to litigation. Indeed, good tax professionals will often seek to avoid costly and time-consuming litigation, if possible, by utilizing various...more
On July 1, 2022, the IRS, Director of Exempt Organizations issued an array of final adverse determinations with respect to organizations seeking exemption under 26 U.S.C. sections 501(c)(3), 501(c)(4), and 501(c)(7). In these...more
Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more
An employee stock ownership plan (ESOP) is a type of tax-qualified retirement plan. ESOPs are designed to invest primarily in qualifying employer securities, as defined in applicable tax rules....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more
In a private letter ruling (PLR 201918008) publicly released earlier this week, the IRS addressed the statutory safe harbor relating to the allowable term for leases of port and airport facilities financed with tax-exempt...more