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
What is tax-loss harvesting? “Tax-loss harvesting,” in its simplest form, is the sale of a capital asset at a loss to “mop up” tax that would otherwise be due on capital gain from the sale of another capital asset. Capital...more
Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...more
After years of explicitly warning taxpayers that failing to report or underreporting income from transactions involving digital assets would lead to criminal charges, federal prosecutors are now beginning to follow through on...more
Charitable Giving Update- According to a recent report on charitable giving, the number of donors at every level of giving dropped during the first three quarters of 2022. The number of new donors was down by over 19...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more
On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more
Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more
U.S. taxpayers have an obligation to both report their cryptocurrency transactions to the IRS and pay taxes on it. Individuals who hold on to their cryptocurrencies as an investment are subject to short- and long-term capital...more
As cryptocurrencies such as Bitcoin rise in popularity, government regulators repeatedly try, and often fail, to control its use as a tax shelter. Agencies such as the IRS struggle with determining the best way to tax...more
In the senior living area, a taxpayer that is selling a community may look to avoid recognizing gain on the sale by entering into a Section 1031 like-kind exchange with respect to the real estate. The tax rules generally...more
Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
Definition of a broker is debated The Biden Administration’s 2021–2022 Priority Guidance Plan (the Plan) supports a push from the IRS and the US Treasury to more closely scrutinize the virtual currency industry....more
Cryptocurrency is more accessible than ever before. Banks are continuing to both implement procedures for and, in some cases, develop their own cryptocurrencies. Paypal allows users in the U.S. to buy, sell and hold select...more
In the Beginning- From the dawn of recorded history, those who have the means have purchased or otherwise financed the work of those whom we call artists – talented individuals capable of producing what we call works of...more
What a Mess- A “perfect storm” may be defined as a critical state of affairs arising from the convergence of a number of negative factors, often after the unexpected introduction of some catalytic event. The situation...more
Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more
On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more
On Oct. 9, 2019, the Internal Revenue Service (the “Service”) issued Revenue Ruling 2019-24 concerning the tax consequences of virtual currency hard forks, as well as FAQs on the taxation of virtual currency generally. This...more
During the month of October 2019, IRS issued Revenue Ruling 2019-24, FAQ’s on Virtual Currency Transactions and a DRAFT Form of Schedule 1, which, for the first time presents the question: “At any time during 2019, did you...more
We all read the headlines. Virtual currencies are a hot button topic. Even Facebook is developing their own virtual currency. It is easy to understand the attraction. The use of a virtual currency is anonymous. Account...more
On September 19, 2018, the House Ways and Means Committee wrote a letter to the IRS urging the IRS to “issue updated guidance, providing additional clarity for Taxpayers seeking to better understand and comply with their tax...more
La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more
The last Notice issued by the IRS on Cryptocurrency was Notice 2014-21 posted on March 25, 2014 providing guidance in the form of answers to frequently asked questions. ...more