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
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
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
The recent federal district court decision in Faulk Company, Inc. v. Xavier Becerra, et al., No. 24-cv-00609-P (N.D. Tex. 2025) significantly alters the primary mechanism used by the U.S. Department of Health and Human...more
The Trump administration is continuing its offensive against the Internal Revenue Service by proposing a $2.5 billion cut to the agency’s budget for FY2026. In the White House’s “skinny budget” released on May 2, the IRS’s...more
If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more
The 2022 Inflation Reduction Act (the “IRA”) allocated $80 billion in funding to the Internal Revenue Service (“IRS”), much of which was earmarked for increased enforcement efforts. After some starts and stops, that funding...more
This session of the Private Client West Cost Forum 2024 explored the current state of audits and tax controversy and shared practical advice to prepare for challenges ahead of a contest with the IRS or Franchise Tax Board...more
Anyone who thought blockchain would keep their cryptocurrency transactions private from the IRS needs to think again. According to the First Circuit’s recent holding, cryptocurrency users do not have a Fourth Amendment...more
The Internal Revenue Service (IRS) recently issued a news release identifying five new signs that a business’s Employee Retention Tax Credit (ERC) may be incorrect. It has also begun issuing a third round of letters denying...more
CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more
Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more
State attorneys general, the IRS, and other regulators are focused on “interested party” (conflict-of-interest) transactions in the healthcare and nonprofit sectors. While these transactions are generally permissible and may...more
The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more
Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more
Crypto Exchanges Launch Institutional Platform, LATAM Stablecoin - A major U.S. cryptocurrency exchange recently announced the launch of an institutional platform “aimed at institutions, asset managers, hedge funds and...more
The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more
The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims. This surely will come as a relief to taxpayers who...more
The Inflation Reduction Act (IRA), enacted in August 2022, appropriated billions of dollars in additional funding to the Internal Revenue Service (IRS). The IRS has begun allocating funds, including investing in artificial...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
In an extraordinary development, the IRS has halted its processing of Employee Retention Credit (“ERC”) refund claims as it struggles to keep up with the massive number of claims filed within the last several months. The...more
There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more
Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more