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
International business and offshore investment and banking create genuine risk and exposure with the IRS. This extends to real estate ownership outside of the U.S. and other offshore-related financial activities, which raise...more
On 1/21/25, the IRS issued Bulletin Issue Number: 2025-02 to remind the FATCA Responsible Officer that Certifications are due 7/1/25 for the Certification period ending December 31, 2024. The Bulletin also provided a...more
On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more
In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more
On June 18, 2014, the Internal Revenue Service (IRS) announced major changes to its 2012 Offshore Voluntary Disclosure Program (OVDP) and streamlined procedures. The modifications provide new options to help both taxpayers...more
Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more
On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more
The Internal Revenue Service (IRS) recently announced in Notice 2014-33 that 2014 and 2015 will be transitional years from an administrative and enforcement perspective regarding the implementation of the Foreign Account Tax...more
The Internal Revenue Service Large Business and International Division (LB&I) administers United States tax law for corporations, partnerships and individuals with assets greater than $10 million. These taxpayers typically...more
The U.S. information reporting and withholding tax regime known as "FATCA"[1] was signed into law on March 18, 2010. In the nearly four years since, the attention of international financial institutions of every variety,...more
SEC and EU Supervisory Cooperation for Asset Management Industry - On July 19, the SEC announced that it signed various memoranda of understanding with the financial regulators of 25 member states of the EU and 3...more
U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more
On January 17, 2013 the Internal Revenue Service issued long-awaited final regulations that implement the Foreign Account Tax Compliance Act (FATCA), the new reporting and withholding tax regime that applies to foreign...more
Tax lawyer Stuart Schabes co-presented “FATCA – 2013 and Beyond” at The Perfect Storm: US Tax Legislation and IRS Compliance 2013, a program hosted by Philip Stein & Associates and ERM. The discussion included: ...more
In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more
On October 24, 2012, the Internal Revenue Service ("IRS") and the Department of Treasury ("Treasury") issued an announcement that extends certain timelines for the implementation of Foreign Account Tax Compliance Act (FATCA)....more
On October 24, 2012, the U.S. Internal Revenue Service (IRS) issued Announcement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA (Announcement). The Announcement provides that final regulations (Final...more
The U.S. Department of the Treasury (Treasury) issued joint statements with the governments of Japan and Switzerland on June 21, 2012 outlining a new framework for foreign financial institutions (FFIs) in those countries to...more
On February 8, 2012, the Internal Revenue Service (“IRS”) announced the release of proposed regulations (the “Proposed Regulations”) for the next phase of implementing reporting and withholding provisions of the HIRE Act...more
The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more
On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more
On February 8, 2012, Treasury and the IRS issued comprehensive proposed regulations (Proposed Regulations) that would, when finalized, implement the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010....more