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
The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
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 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
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
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
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
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
In the years since COVID-19 shut down the country, many businesses applied for the Congressionally-authorized Employee Retention Credit (ERC), a valuable relief program created during the pandemic to support businesses who...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
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more
Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s...more
On a webinar hosted by the New York University Tax Controversy Forum on June 18, 2020, Douglas O’Donnell (head of the IRS Large Business and International Division/IRS-LBI) stated that the IRS will begin a new campaign to...more
On March 30th, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report which concluded, based on its estimates, that the IRS could have collected significant additional tax revenue from cannabis...more
If you are in the cannabis industry, you should already know Section 280E of the Internal Revenue Code. It consists of only one sentence...more
On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more
The IRS might want to audit (also known as a review or an examination) an Individual Taxpayer’s accounts and financial information to verify that the information that the Individual Taxpayer is reporting is compliant with the...more
The new partnership audit rules apply to tax years beginning in 2018. While the new rules eliminate the need for a tax matters partner, that role is replaced with a new role called the partnership representative (PR). ...more
On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more