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Harvard University’s tax-exempt status has been questioned by the Trump Administration—with Harvard responding that there is no legal basis for a revocation. The Administration’s action impacting Harvard flows from its letter on policy...

The most prominent tax characteristic of a partnership or LLC is that these entities are flow-through entities for tax purposes. Consequently, the entities do not pay taxes themselves. Rather, they report to the IRS their income and the partners'...

Tariffs are generally considered a regressive form of taxation—that is, a tax burden that falls more heavily on lower-income individuals than on higher-income individuals, relative to their incomes. When tariffs are applied, the cost of goods subject...

Real property transactions involving easements granted in the name of conservation can yield tax deduction benefits to the grantor. While the validity of charitable contributions in this area is subject to scrutiny and deduction claims are prone to challenge...

As the population ages and more taxpayers live on fixed incomes, both federal and state governments face challenges in determining the appropriate level of taxation for retirees. For federal income tax purposes, retirement income is generally fully includable...

Explore the taxation of business profits under U.S. international tax treaties, focusing on the critical role these treaties play in preventing double taxation and clarifying cross-border tax obligations. This practice note explores the concept of permanent...

In 2025, navigating the IRS's tax collection process is more critical than ever, as changing tax laws and economic shifts demand vigilance from both individuals and businesses. The IRS, armed with a formidable team of Revenue and Appeals Officers...

Executive Order 14210 issued by the Trump Administration calls for a "critical transformation of the Federal bureaucracy," which provides, among other things, submission of a plan by the Director of the Office of Management and Budget (OMB)...

A limited liability company (LLC) can be taxed as an S corporation, but an S corporation is not always a good choice. Learn the tax options available to LLCs and the advantages and disadvantages of electing to be taxed as an S corporation. When evaluating...

The U.S. branch profits tax (BPT) is a critical component of the federal tax system, ensuring foreign corporations with U.S. branches face a tax burden similar to U.S.-incorporated subsidiaries. Imposed at a 30% rate on the "dividend equivalent amount...

Virtually every state has some type of franchise tax or fee that is imposed on domestic and/or foreign corporations as part of the cost of doing business in the state. The measure of franchise taxes varies from state to state. While some franchise taxes...

A business entity that is treated as a disregarded entity for tax purposes is generally ignored for U.S. federal income tax purposes even though it is a separate legal entity for state law purposes. While disregarded entities offer significant advantages...

For tax practitioners, understanding tariffs is one of the keys to unlocking the complexities of international trade. Tariffs not only shape the cost structure of imported goods but also ripple through pricing strategies, supply chain decisions, and overall...

The Creating Helpful Incentives to Produce Semiconductors Act of 2022 (CHIPS Act), Pub. L. No. 117-167, § 107, was signed into law by President Biden on August 9, 2022. With the goal of incentivizing semiconductors and semiconductor manufacturing...

As we enter 2025, the renewal of the Tax Cuts and Jobs Act of 2017 (TCJA) is front and center for Republicans, who hold majorities in both chambers of Congress. Despite internal divisions and procedural hurdles, Senate Majority Leader John Thune aims...

The allocations that partners establish in their partnership agreement determine each partner's distributive share. A partner’s distributive share is that fraction of a partnership's items of income, gain, loss, deduction, and credit that...

As we step into the new year, it's a great time to reflect on any changes in partnership interests that took place in 2024. The sale or exchange of a partnership interest is only one way in which partnership interests can change. For example, if a...

With Republican control of the White House, the Senate, and the House of Representatives, President-elect Donald J. Trump is expected to support a wide range of policies including raising tariffs and lowering taxes. Possibilities include $2 trillion in...

The Inflation Reduction Act provided special funding to the IRS, much of it targeted for IRS enforcement efforts. While funding for this effort was originally appropriated at $45.6 billion, a subsequent Congress reduced the amount by about $20 billion...

The Department of the Interior's (DOI's) Payments in Lieu of Taxes (PILT or PILOT) program, is a federal initiative that offsets the loss of property tax revenue for local governments due to the presence of nontaxable federal lands within their...

Many tax-related ballot issues were raised across all 50 U.S. states and the District of Columbia for the 2024 election year. The issues spanned measures related to income tax, sales and use tax, property tax, and miscellaneous taxes, put out there for...

The 2024 landmark case , Loper Bright Enters. v. Raimondo, 144 S. Ct. 2244 (June 28, 2024) , officially jettisoned the 40-year-old Chevron two-step standard for statutory interpretation. Will Loper Bright motivate the Treasury Department and IRS to now...

Publicly traded companies can offer their employees access to purchase employer stock on a discounted basis, using an employee stock purchase plan that complies with I.R.C. § 423 . These plans are broad-based programs that, during an “offering...

NIL rights refer to the ability of student-athletes to earn compensation for the use of their name, image, and likeness. This includes activities such as endorsement deals and social media promotions, allowing student-athletes to monetize their personal...

A listed transaction is a transaction that is the same as or substantially similar to one of the types of transactions the IRS has determined to be a tax avoidance transaction and identified as such by notice, regulation, or other form of published guidance...