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
Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more
Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more
One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more
If you wish to create a new trust or update an existing estate plan, you will need skill and expertise across many disciplines: tax, estate planning, and legal services. Look for a service provider who can seamlessly...more
Tax developments - Pillar 2’s viability: Perspectives from industry leaders - In a prior edition of Tax Bytes, we explained how “some, including the Finance Ministers of Hungary and India, have questioned the viability...more
This note only addresses subsidiaries of Nordic companies. Branch offices are rarely attractive for foreign companies because they result in direct exposure for the foreign company to liability in the U.S. and jurisdiction by...more
A common strategy many wealth management firms recommend is ensuring that as much as 30% of your portfolio includes foreign investments and securities. What is the potential tax impact of foreign investments? One of the keys...more
The IRS has clearly identified legitimate reasons why "U.S. Persons" would establish or maintain ownership in a foreign trust. However, a foreign trust creates complex IRS reporting requirements for US taxpayers who own a...more
Are you involved in offshore or foreign corporate ownership and investments? Do you have real property, assets, or foreign bank or investment accounts? U.S. taxpayers with offshore business interests, holdings, investments,...more
This CLE/CPE webinar will provide tax counsel with a thorough and practical guide to structuring strategies and tax considerations for foreign investors in U.S. assets utilizing leveraged blockers and other tax planning...more
La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more
Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more
While there is an anticipation of greater predictability under a President Joe Biden, which is critically important to the commercial real estate industry, expected and potential changes in trade, taxation, housing and health...more
On 9/14/20, the IRS announced 4 New Compliance Campaigns . One Campaign addresses FIRPTA (Foreign Investment in Real Property Tax Act of 1980) Reporting Compliance for Non-Resident Aliens (NRAs). FIRPTA authorized the United...more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
On December 13, 2018, the Internal Revenue Service issued proposed regulations that eliminate certain types of withholding under Sections 1471-1474 of the tax code, which are commonly referred to as FATCA. ...more
More than 25 years after the IRS announced its position that foreign partners were subject to tax on the gain from the sale of the partnership interests, the Tax Court decided in favor of taxpayers. ...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
Since FATCA’s implementation in 2010, investing in a Passive Foreign Investment Company (PFIC) is a questionable decision. PFICs are reportable investments and their tax regime is punitive. Under FATCA, US Taxpayers’...more
The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more