Taxing Intelligence: AI's Role in Modern Tax Administration
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
Navigating Contractor vs. Employee Classification
Insider Transaction Traps for the Unwary
Multijurisdictional Employers, Part 1: Independent Contractors vs. Employees
The Presumption of Innocence Podcast: Episode 60 - Enforcement Priorities of the Second Trump Administration: Employee Retention Tax Credit
REFRESH Steps for Launching a New Charitable Corporation
The Presumption of Innocence Podcast: Episode 58 - Enforcement Priorities of the Second Trump Administration: IRS Investigations
Are Overtime Wages and Tips Exempt From Income Tax? What Employers Need to Know to Prepare
Nonprofit Basics: IRS 10-Course Charity Workshop
Nonprofit Basics: Unrelated Business Income Tax: Debt Financed Income - Part 3
The Demystification of Employee Retention Credits for Private Equity Deals — PE Pathways Podcast
Nonprofit Basics: Unrelated Business Income Tax: Modifications and Exceptions - Part 2
Navigating the Inflation Reduction Act: Insights on Brownfield Energy Community Credits - Energy Law Insights
4 Key Takeaways | Analyzing the Top Income Tax Cases in 2024
REFRESH Nonprofit Basics: Year-End Thoughts and New Year To-Do List
What's the Best Transaction Structure for My Sale?
Year-End and Trending Tax Considerations for Health Care Practices
Nonprofit Basics: International Grantmaking – Part 2 Income Tax Withholding Rules
PODCAST: Williams Mullen's Benefits Companion - Tax Relief and Possible Retirement Plan Resources for Hurricane Victims
A frequent question we get from clients and colleagues is if a tax attorney or certified public accountant (CPA) — or both — are needed. ...more
In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more
Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025. July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for...more
The IRS has issued new guidance to its Large Business and International Division (LB&I) in an attempt to expedite audits. The interim guidance, released on July 23, 2025, outlines procedural changes that will further...more
Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more
On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more
On July 23, 2025, the IRS issued guidance on audits of large corporate taxpayers. This guidance falls squarely in line with previous IRS statements at conferences, as well as its prior guidance about making examinations more...more
On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more
The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more
A recent memo from the IRS's Large Business and International (LB&I) Division indicates an intention to resolve audits efficiently and provide taxpayers with opportunities to quickly settle and resolve issues....more
New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more
Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more
A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more
It is an uncertain time to be a tax-exempt public charity or private foundation. The federal government has recently scrutinized certain tax-exempt organizations (see here), and draft congressional legislation proposed a tax...more
The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for the upcoming fiscal...more
On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more
The Internal Revenue Service (IRS) began terminations of employees on February 20, 2025, with initial news reports of layoffs set to 6,000 terminations and a stated intent to downsize its workforce by upwards of 50 percent as...more
Welcome to EO Radio Show – Your Nonprofit Legal Resource. Many nonprofits today are worried about recent federal actions that may bring governmental scrutiny to their stated charitable mission and activities, such as audits,...more
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more
As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more
President Donald Trump has repeatedly threatened to strip the tax-exempt status from colleges and universities. Most recently, on May 2, Trump announced in a social media post, “We are going to be taking away Harvard’s Tax...more
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
As a result of President Trump’s recent social media posts regarding Harvard University’s tax-exempt status, some institutions of higher education (IHE) have expressed concerns over whether the Internal Revenue Service (IRS)...more
I love Las Vegas. Great restaurants, great shows, and five trips in a row without dropping a nickel into a slot machine. Why? Because I hate gambling. I hate losing even more. Honestly, just getting out of bed every morning...more