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
Business succession planning and estate planning are often linked together, particularly in the case of closely held family businesses. In the case of a shareholder who wishes to pass along their shares of an S corporation as...more
Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more
In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its...more
Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more
In response to Internal Revenue Code Section 2001(g)(2), enacted as part of the 2017 Tax Act, in which the Secretary of the Treasury was directed to prescribe regulations to carry out IRC Section 2001(g) with respect to the...more
Home for the Holidays? Our last post considered the division of a business between family members as a means of preempting the adverse consequences that will often follow disagreements within the family as to the...more
Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more
I. INTRODUCTION - This outline is a selective and evolving review of the history of the modern federal estate tax. It originated during the attempts to repeal the estate tax in President Clinton’s second term and...more
Proposed changes to Internal Revenue Code (IRC) § 2704, which would impact the valuation of transfers of family business interests at death, come at an interesting time politically given the Trump Administration’s desire to...more
The election of Donald Trump and Republican majorities in U.S. Congress make the future of the federal transfer tax system (gift, estate and generation-skipping transfer (GST) taxes) uncertain. President-elect Trump and...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
IRS issues new proposed rules aimed at eliminating valuation discounts for transfers of interests in family-controlled entities. Clients considering making transfers of interests in such entities should act soon....more
Earlier this month, the IRS issued long-awaited proposed regulations under Section 2704 of the Internal Revenue Code that, if adopted, will have a substantial impact on traditional estate planning techniques commonly utilized...more
On August 2, 2016, the Internal Revenue Service (IRS) released proposed regulations that, when finalized, will affect clients holding and transferring interests in family-controlled entities. Family limited partnerships...more
Recently proposed Treasury Regulations (“Proposed Regulations”), if enacted as proposed, would curtail valuation discounts that currently reduce the value of certain business interests transferred during life or at death for...more
Action Item: Owners of family businesses and investment entities (such as family limited partnerships, limited liability companies (“LLCs”), and corporations) are urged to consider making transfers of interests in those...more
High net worth families often utilize family entity structures, such as limited partnerships or limited liability companies, in order to provide for the coordinated management of family assets and move wealth to younger...more
Long-awaited proposed regulations under section 2704 of the Internal Revenue Code, released on August 2, 2016, would make sweeping and very significant changes to the valuation of interests in many family-controlled entities...more
After years of slow boiling anticipation, statements made by the IRS and the Treasury this year heated up the conjecture and anticipation which finally came to a head on August 2, 2016. I’m of course talking about the...more
A profound effect on family controlled businesses may be in store when proposed Treasury Regulations under Section 2704 of the Internal Revenue Code come to pass. Under the new regulations, taxpayers would be precluded from...more
IRS regulations anticipated for release as early as this September may further restrict valuation discounts. The exact scope of the regulations is unknown, but the regulations will likely make it more difficult for taxpayers...more
The IRS may take action very soon to eliminate or reduce a widely used and valuable family business entity wealth transfer strategy. The window of opportunity to take advantage of this strategy may close within the next month...more
Upcoming IRS regulations may significantly limit and reduce planning opportunities to transfer minority interests in closely held entities to family members and increase the transfer tax cost associated with moving such...more