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Senate Version of One Big Beautiful Bill Act Clarifies Foreign Entity Restrictions on Renewable Energy Tax Credits

The Senate Finance Committee recently released its own draft of the “One Big Beautiful Bill Act” (the Bill) previously passed by the House as H.R. 1. Both the House and Senate versions of the Bill impose restrictions on...more

IRS Cutbacks May Impact Healthcare M&A Transactions

Kevin’s practice involves guiding clients through the complexities of federal, state, local and international taxation. Kevin routinely advises business entities, tax-exempt organizations and high net worth individuals on a...more

Executive Order Highlights Risks to Nonprofit Tax-Exempt Status

President Trump’s executive order (EO) “Restoring Public Service Loan Forgiveness,” issued March 7, 2025, sets limits on student loan forgiveness under the Public Service Loan Forgiveness (PLSF) program. But the language used...more

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

IRS Takes Aim at High Earners, Large Partnerships, and Corporations Using AI

When the Inflation Reduction Act was passed last year, the legislation included massive funding increases for the Internal Revenue Service (IRS). The initial narratives regarding the funding increases focused primarily on...more

IRS Signals Increased Reliance on Partnership Anti-Abuse Rules

Speaking at a Practicing Law Institute program on April 25, Internal Revenue Service (IRS) lawyer Clifford Warren indicated that the IRS has been using the anti-abuse rule of Treasury Regulation Section 1.701-2 to scrutinize...more

Inflation Reduction Act to Greatly Increase IRS Funding

The Inflation Reduction Act of 2022 (IRA) includes increased Internal Revenue Service (IRS) funding in the amount of approximately $80 billion over ten years. According to a Congressional Research Service report, the law...more

U.S. Government Targets Digital Assets for Additional Revenue

On Friday, November 5, the House of Representatives passed the Bipartisan Infrastructure Framework bill, formally known as the Infrastructure Investment and Jobs Act (the "Act"). Of particular note, the Act contains...more

Supreme Court Declines To Hear Challenge To IRS Enforcement Of Cannabis Tax Rules

On June 21, 2021, the U. S. Supreme Court declined to hear Eric D. Speidell, et al., Petitioners v. United States, which sought to overturn the Tenth Circuit Court of Appeals’ 2020 opinion on Speidell v. United States. In...more

American Families Plan Steps Up IRS Focus On High-Net-Worth Individuals

On May 20, 2021, the Department of the Treasury released the American Families Plan tax compliance agenda, detailing the tax compliance initiatives in President Biden’s American Families Plan. The tax compliance agenda is...more

U.S. Tax Court Finds "Disqualified Person" Definition For Nonprofit Excess Benefit Rules Is Expansive

On May 17, 2021, the U.S. Tax Court issued a Memorandum Opinion in Vincent J. Fumo v. Commissioner, T.C. Memo. 2021-61, regarding the definition of a “disqualified person” under I.R.C. section 4958(a)(1). Managers of...more

Tax Court Rules In Favor Of Generic Drug Manufacturer On Deductibility Of Patent Litigation Expenses In Connection With ANDAs

On April 27, 2021, the United States Tax Court held that legal fees incurred by generic drug manufacturers in connection with “Section 271(e)(2)” patent infringement suits are deductible as ordinary business expenses and need...more

IRS Updates Tax Filing And Payment Guidance

On Friday March 20, 2020 the Internal Revenue Service issued IRS Notice 2020-18 regarding federal income tax payments and income tax returns due on April 15, 2020. The guidance supersedes and replaces IRS Notice 2020-17 that...more

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