Maryland's Sales Tax on IT and Data Services
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5 Key Takeaways | Artificial Intelligence: What Tax Professionals Need to Know
Avoiding Tax Consequences During Oil & Gas Restructurings
The Internal Revenue Service (IRS) continued recent improvements to the process for making elections under Section 83(b) of the Internal Revenue Code of 1986 (the Code). Until last year, an 83(b) election was made in a...more
Section 1202 of the Internal Revenue Code provides a capital gains exclusion for certain qualified small business stock (QSBS) when a stockholder sells the same. This gain exclusion impacts venture-backed startups, angel...more
Taxpayers invest to make money and hope to earn a decent return on their investments. Tax-loss harvesting can be used as part of a taxpayer’s overall investment strategy without affecting investment returns, while offsetting...more
In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more
On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election (“Form 15620”), standardizing the requirements to make an election pursuant to Section 83(b) (“Section 83(b) Election”), with...more
At the beginning of this series, I mentioned briefly that taxpayers can use tax-loss harvesting approaches in tandem with a number of investment strategies, which we will go into in more detail in Part III. Many of these...more
New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more
On July 16, 2025, the House Ways and Means Committee held a hearing on crypto taxation. Congress and the Administration did not address tax issues in the most recent Digital Asset legislation, as previously discussed here. ...more
When an employer (or the proper withholding agent, like a plan administrator) issues a retirement benefit, there is generally an obligation to withhold income tax on the payment and to report the payment on Form 1099-R....more
Revenue Ruling 2025‑15 (available here) provides guidance on withholding and reporting obligations when a plan participant or beneficiary fails to cash a distribution check and a replacement check is issued. As discussed...more
Last year, the US Internal Revenue Service (IRS) released Form 15620 for taxpayers to make elections under section 83(b) of the Internal Revenue Code, an important part of US tax planning for founders, employees, board...more
The IRS has released Revenue Ruling 2025-15, which clarifies the federal tax withholding and reporting responsibilities of retirement plan administrators when a distribution check is issued but remains uncashed and a...more
The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more
The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for the upcoming fiscal...more
In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”. Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more
In California FEHA settlements, plaintiffs often recover damages for both emotional distress and lost wages—but how are those payments taxed? Employers often compel an allocation in damages between wages (economic loss) and...more
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
Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more
Former member of Congress and professional auctioneer Billy Long has been formally sworn in as Commissioner of the Internal Revenue Service. Following lengthy delays during his nomination process, Long was confirmed by the...more
As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more
On May 22, 2025, the House of Representatives passed by a one-vote margin the “One Big Beautiful Bill Act” (the “House Bill”), which has now moved to the Senate for consideration. This Memorandum discusses the House Bill’s...more
In just under two weeks, the House of Representatives introduced, modified and passed the One Big, Beautiful Bill of 2025 (the “House Tax Bill”). This Memorandum addresses a new proposed tax on certain persons sending money...more
Every conveyance of property or of an interest in property from one person to another is prompted, or at least influenced, by economic considerations. The parties to the transaction may swap properties, or one party may...more
A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit...more
On May 1, 2025, the Internal Revenue Service (IRS) released Revenue Procedure 2025-19, which provides the 2026 inflation adjusted limits related to Health Savings Accounts (HSAs) and High Deductible Health Plans (HDHPs)....more