Under IRC § 103(b)(2) , interest which would otherwise be excluded from gross income under IRC § 103(a) is instead subject to federal income taxation if the obligation is classified as an arbitrage bond. Arbitrage bonds are one of several exceptions to...
It’s not unusual for large employers to own or lease private jets to transport their top executives to business locations. All business travel is a tax-deductible business expense (and generally the costs related to the jet), but what if there’s a personal...
Section 527 of the Internal Revenue Code provides a broad tax exemption for Political Action Committees (PACs) involved only in campaign activity. Section 527 applies only to "political organizations." For a PAC to qualify, it must be organized and operated...
A private letter ruling request is a request to the IRS by a taxpayer (an individual, business, or other entity) requesting the IRS to address, in writing, a specific tax situation that applies to the taxpayer, inquiring about its status for tax purposes or the...
Section 311, Title III, of the USA Patriot Act (the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001) amended the anti-money laundering provisions of the Bank Secrecy Act to promote the prevention...
Scroll through our new Practice Videos Resource Kit and sample our vast cross-practice area video collection. Want to learn more about Section 911 issues when working abroad? Or how Section 409A applies to deferred compensation? Grab some ear buds and listen to...
When paying wages that supplement an employee’s standard income, such as when employers pay bonuses, commissions, awards, and even overtime pay and severance, employers can use the supplemental federal tax rate instead of wage withholding tables. The hit...
A conservation easement is a legal agreement between a landowner and an eligible entity that imposes restrictions and/or affirmative obligations on the landowner's property to retain or protect natural or historic resources for the public good. Like a traditional...
The tax code, Section 162(e), prohibits a tax deduction for most lobbying and political expenditures. These include expenditures paid or incurred in connection with (1) influencing legislation; (2) participating or intervening in any political campaign on behalf...
When enacted in 2017, the Tax Cuts and Jobs Act of 2017 (TCJA) introduced the most sweeping changes to the Internal Revenue Code since the Tax Reform Act of 1986. Without Congressional action to extend them, many of the TCJA changes, which were only temporary,...
Sometimes things aren’t what they seem. Take disguised sales in partnerships and other flow-through entities. A disguised sale occurs when a partner supposedly contributes property with a built-in gain to a partnership and then immediately, or a short time...
Because partnership tax items generally flow directly to partners/LLC members, and do not remain with the entity, certain transactions at the entity level can result in tax consequences that the Internal Revenue Code never intended. Consequently, the federal tax...
Completing your employer’s business travel reimbursement form isn’t a fun task—but think of the alternatives. Failing to do so naturally means you won’t get reimbursed. But what if your employer advances you the money instead? Failing to...
The United States has signed income tax treaties/income tax conventions with nearly 70 countries. Tax treaties allow U.S. citizens (and sometimes residents) to be taxed at either reduced income tax rates or exempt from taxation altogether on specified income items...
Legislation called The Tax Relief for American Families and Workers Act of 2024 (TRAFA) is intended to spur innovation and economic growth, allowing corporate taxpayers greater deductions in research and development and interest expense. It also would increase...