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
In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more
In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more
On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs)....more
Turmoil continues to roil the highest ranks of the Internal Revenue Service, as the President has replaced the acting IRS Commissioner that he appointed just last week. As we previously wrote, on Tax Day, the President named...more
Certain micro-captive transactions are back to being reportable. On January 14, 2025, the Treasury Department and the Internal Revenue Service (“IRS”) published final regulations (the “Regulations”) that named some...more
Litigation attorneys have had the ability to defer contingency fees since 1994. You are hard pressed to find another profession that has this tax advantage. Hedge fund managers have been running and winning the “Death Race”...more
The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more
On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year. Persons engaged in...more
On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information. Specifically, Kraken was ordered to produce the...more
On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more
As previously discussed here, the IRS published guidance in December 2022 effectively postponing the January 1, 2023 effective date for certain digital asset broker reporting rules until final regulations are promulgated. To...more
As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more
A new tax rule will see the Internal Revenue Service (IRS) gain information on income small businesses receive via transactions on popular payment applications. As of Jan. 1, 2022, businesses that accept more than $600 per...more
Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more
In Washington: President Biden on Tuesday began what is expected to be a weeks-long sales pitch to tout the new coronavirus relief package. Biden visited Smith Flooring in Chester, Pennsylvania, a small business that received...more
Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more
On October 2, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued Revenue Produce 2019-40 (the “Revenue Procedure”) and proposed regulations (the “Proposed Regulations”)...more
This week, I was honored to again have the opportunity to participate as a speaker at the Internal Revenue Service’s Nationwide Tax Forum 2019 in Washington, D.C. Through a generous grant provided by the American Coalition...more