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
The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more
The Internal Revenue Service (“IRS,” or the “Service”) issued guidance on June 17, proposing new regulations and releasing a revenue ruling to challenge the use of basis-shifting transactions by complex partnerships. In...more
In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more
Under Section 6417 of the Internal Revenue Code (IRC), “applicable entities” and certain electing taxpayers can elect to treat various renewable energy tax credits as payments against tax, essentially making those credits...more
The Internal Revenue Service plans to deploy thousands of new hires to expand audits of partnerships and high net wealth individuals. As part of a larger transformation at the agency, it is using some of the $60 billion in...more
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
On March 28, 2022, the Biden Administration proposed certain limited changes to the taxation of partnerships. In short, the Administration’s proposals would (i) prevent related partners in a partnership that has made a...more
On March 28, 2022, the Biden Administration proposed to tax “profits” or “carried” interests as ordinary income and impose self-employment tax on income and gains from these interests for certain partners in investment...more
On January 25, 2022, the IRS and Treasury proposed regulations that would treat U.S. partners, instead of their partnerships, as PFIC shareholders for making qualified electing fund, mark-to-market, or purging elections,...more
In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more
Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 20 – 24, 2021. September 22, 2021: The US Department of the Treasury (Treasury) and...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 18, 2021 – January 22, 2021... On January 20, President Biden’s chief of staff, Ronald...more
On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more
On April 23, the Treasury Department and the Internal Revenue Service (the "IRS") issued helpful proposed regulations under section 512(a)(6) of the Internal Revenue Code (the "proposed regulations"). Section 512(a)(6) was...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13 – 17, 2020. January 13, 2020: The IRS published an information letter relating to the...more
2018 was a very active year for tax developments. The big story was the application of the substantial reforms of the Tax Cuts and Jobs Act of 2017, which took initial effect in 2018. But there were several other developments...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...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, with emphasis on how such developments impact the energy, technology...more
The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
In this episode of Verrill Voices: Lawyers on Tap, Verrill Dana attorneys Jennifer Green and Jonathan Dunitz discuss the importance of entity formation to the overall success of a brewery business, and the differences between...more