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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
The June 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.00%, which is the same as the April 2025 Section 7520 rate...more
In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more
The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more
There have been many recent tax developments for U.S. expatriates. It is essential for U.S. citizens residing outside the United States and those considering an expat life to understand their responsibilities as U.S....more
The House’s recent budget bill includes significant tax legislation; however, it does not include any crypto tax provisions. Additionally, the GENIUS Act, which recently moved forward in the Senate and would provide a...more
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
In the context of medical coverage, the terms “Preventive Services” and “Preventive Care” are often used interchangeably. The two terms, however, have very different meanings. Understanding the difference can have significant...more
On April 17, 2025, the IRS issued Notice 2025-23, which announced its intent to publish a notice of proposed rulemaking to remove Treasury Regulations Section 1.6011-18 that identifies certain partnership basis adjustment...more
A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit...more
On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a taxpayer-friendly legislative proposal. While it is uncertain whether the TAS Act...more
What is an EIN? An EIN is a federal tax ID number for an entity, estate, trust, or other organization. For example, the following are generally required to obtain an EIN: partnerships, limited liability companies (“LLC”),...more
News that Steward Health Care executives may lose millions in unqualified retirement savings due to the company's use of a "rabbi trust" has sent a jolt through the ranks of corporate leadership. Steward's deferred...more
The IRS has announced the 2026 cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and excepted benefit health reimbursement arrangements...more
Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...more
On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs)....more
The federal rule that would have required crypto platforms to report users’ transactions to the IRS has officially been scrapped. President Trump signed a joint congressional resolution overturning the so-called DeFi...more
The Internal Revenue Service (IRS) recently announced (see Revenue Procedure 2025-19) cost-of-living adjustments to the applicable dollar limits for health savings accounts (HSAs), high-deductible health plans (HDHPs), and...more
On May 1, 2025, the IRS released Rev Proc 2025-19 which updated for 2026 the limits applicable to certain health and welfare plans, including the following key limits...more
The Internal Revenue Service has released Rev. Proc. 2025-19 announcing the inflation-adjusted limits for high deductible health plans (HDHPs) and health savings accounts (HSAs) in 2026. The updated 2026 limits are as...more
On May 1, 2025, the IRS announced the Health Savings Account limits for 2026. With respect to contribution limits, the limits are slightly higher than the ones for 2025 and the required deductible and out-of-pocket maximums...more
On April 17, the Internal Revenue Service issued a notice announcing its plans to withdraw a set of controversial regulations, finalized in January of this year, aimed at transactions designed to shift tax basis in...more
The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more
On April 17, 2025, the U.S. Internal Revenue Service (the “IRS”) issued Notice 2025-23 (the “Notice”), announcing its intention to withdraw the recently released final regulations final regulationsthat classify certain...more
Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more
Tuesday, while millions of Americans were busy finalizing their tax returns, the President named a former IRS criminal investigator as the tax agency’s new leader. Gary Shapley, a former IRS special agent who gained...more