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
June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative for Missouri’s 7th congressional district from 2011 to 2023. His...more
On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more
On June 9, 2025, Sullivan & Worcester submitted a comment letter to the Internal Revenue Service (IRS) in response to Notice 2025-6, which requests public input on the possible expansion of the cloud transaction framework...more
Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more
The IRS recently released new FAQ guidance providing a simplified procedure for addressing income tax amendments and refund claims related to Employee Retention Credit (ERC) determinations. See IRS FAQs. Taxpayers claiming...more
On March 20, 2025, the IRS updated its guidance to employers that claimed the employee retention credit (ERC). The updated guidance materially differs from prior IRS guidance of how and when employers should report the income...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more
On June 30, 2023, the United States Department of the Treasury (“Treasury”) published Final Regulations as guidance on the transition from the use of the Interbank Offer Rate (IBOR) to the Secured Overnight Financing Rate...more
On April 21, 2023, the IRS released Chief Counsel Advice Memorandum 202316008 (the “CCA”), which provides that cryptocurrency protocol changes are not treated as realization events and do not give rise to gross income for...more
Electric vehicle and electric battery manufacturers and critical mineral producers will want to take note of a notice of proposed rulemaking (NPRM) on Section 30D of the Internal Revenue Code of 1986, as amended, released by...more
On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; and (2) TG...more
At the end of 2022, the Department of the Treasury and the Internal Revenue Service (together, the “IRS”) issued two sets of guidance – a final rule and a proposed rule – addressing the application of certain provisions of...more
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more
As noted in yesterday’s post, the IRS published Notice 2022-61 regarding the prevailing wage & apprenticeship requirements. In addition, the Department of Labor yesterday issued two Frequently Asked Question (FAQ) documents:...more
The Internal Revenue Service (IRS) was one of the first United States regulators to provide guidance on the tax treatment of virtual currencies such as Bitcoin. Starting back in 2014 with its release of Internal Revenue...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more
On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more
As the IBOR transition continues, business teams have frequently heard from their tax departments and advisors that amending existing contracts to add IBOR replacement mechanics or replacing an IBOR rate with a new rate can...more
On October 21, 2021, the Internal Revenue Service (the “IRS”) released Notice 2021-56 (the “Notice”), which sets forth the additional requirements a limited liability company (“LLC”) must satisfy to obtain a determination...more
On April 9, 2021, the Internal Revenue Service (IRS) released Chief Counsel Advice memo 202114020 (Hard Fork CCA), which details the potential tax consequences for taxpayers who held Bitcoin prior to the August 1, 2017,...more
On April 9, 2021, the Internal Revenue Service (Service) released Chief Counsel Advice 202114020 (the Guidance) regarding the tax consequences to an individual in receipt of Bitcoin Cash (BCH) following the August 2017 hard...more
The Internal Revenue Service (IRS) issued guidance on Thursday, September 10, 2020, to marijuana businesses. The new guidance does not change existing IRS rules, but briefly explains the rules for reporting income, paying...more
On August 8, 2020, President Donald Trump issued an executive order titled “Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster.” The order directed the Secretary of the Treasury to use...more
The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more
On August 28, the IRS issued Notice 2020-65 to provide guidance on the President’s decision to allow deferral of the employee portion of Social Security taxes owing for the rest of 2020 for employees earning up to $104,000...more