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
On January 23, 2025, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the applicable 2024 limits for Puerto Rico qualified retirement plans. Pursuant to...more
The tax advantages for US individuals who become bona fide residents of US possessions can be substantial. These tax advantages have lured more than a few taxpayers to take unreasonably aggressive positions that they are...more
Prompted by congressional scrutiny of the Internal Revenue Service’s (IRS) efforts to root out those abusing lucrative Puerto Rico tax benefits, the agency has committed to devoting more resources to audits of those taking...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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 10, 2022 – October 14, 2022...more
The Tax Court issued its second opinion in Medtronic following a remand by the US Court of Appeals for the Eighth Circuit (Medtronic, Inc. v. Comm’r, 900 F.3d 610 (8th Cir. 2018)) of its earlier decision. In that...more
According to the IRS, the Dirty Dozen represents the worst of the worst tax scams. The Dirty Dozen is a list that is compiled annually by the IRS in order to alert taxpayers, tax professionals and financial institutions of...more
Auguring a flood of opinions in the remaining weeks of the term, the Supreme Court decided five cases today. Some of them offer support for the media/popular equation of a political party background with jurisprudential...more
Boechler, P.C. v. Commissioner of Internal Revenue, No. 20-1472: This case involves the application of “equitable tolling” in tax “collection due process” cases. This case arose after the IRS sustained a proposed levy on the...more
On January 14, 2022, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 22-01 (CL IR 22-01) announcing the applicable 2022 limits for Puerto Rico qualified retirement plans. ...more
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
In Cotto-Vázquez v. United States, CIV. NO.: 16-2807 (SCC) (D.P.R. March 11, 2021), Miguel Ángel Cotto-Vázquez (Cotto),1 the former four-time Puerto Rican boxing champion, became involved in another fight. This time he faced...more
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
Last year, in response to the COVID-19 pandemic, the United States Congress and the Puerto Rico Department of Treasury (Hacienda) granted favorable tax treatment to coronavirus-related distributions (CRDs) and participant...more
With the fourth quarter of 2020 upon us, it is time to evaluate the year-end amendments that may be needed for retirement plans that are tax-qualified in Puerto Rico. Unlike the Internal Revenue Service, which each year...more
Employers considering reductions in force in Puerto Rico should be aware that the rules on the taxation of severance pay in the United States and Puerto Rico are different. The U.S. rule is straightforward: severance pay...more
On December 28, 2019, the Puerto Rico Department of the Treasury issued Internal Revenue Circular Letter No. 19-17 (CL IR 19-17) announcing the applicable limits for Puerto Rico qualified retirement plans for 2020....more
On May 17, 2019, the Puerto Rico Department of the Treasury (“PR Treasury”) issued Internal Revenue Informative Bulletin No. 19-07, granting an additional extension until June 30, 2019 for employers to request the Federal...more
On December 31, 2018, the Puerto Rico Department of the Treasury (PR Treasury) issued Internal Revenue Informative Bulletin No. 18-24 (IB 18-24) announcing the 2019 applicable limits for Puerto Rico qualified retirement...more
• Part 1 and Part 2 of this series of Holland & Knight alerts described a new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." • In Part 3,...more
On December 15, 2017, the Puerto Rico Department of the Treasury (the “PR Treasury”) issued Tax Policy Circular Letter No. 17-02 (“CL 7-02”) announcing the 2018 applicable contribution limits for qualified retirement plans....more
• Because of the damage Hurricanes Irma and Maria inflicted on the U.S. Virgin Islands and Puerto Rico, the IRS has relaxed the stringent physical presence requirements that individuals typically must satisfy to qualify as...more
The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more
On December 8, 2016, the Puerto Rico Department of the Treasury issued its Tax Policy Circular Letter No. 16-07 (“CL 16-07”), announcing the applicable limits for 2017 for qualified retirement plans. Pursuant to Section...more
On March 11, 2016, the Puerto Rico Department of the Treasury (“PR Treasury”) issued Administrative Determination No. 16-05 (“AD 16-05”), eliminating the requirement to file PR Treasury Form 480.70(OE) for retirement plans...more