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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...

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...

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...

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...

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...

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...

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...

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...

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?...

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...

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...

Taxes are hard to avoid! More than 40 states levy individual income taxes which, with state corporate income taxes, and sales and use taxes, comprise the major source of most state government revenues. Like the federal income tax, individuals are responsible...

The IRS Office of Chief Counsel recently considered consolidated group membership in determining the arm’s length rate of interest chargeable for intragroup loans and making a section 482 adjustment. Under the section 482 regulations, the arm’s...

Statutes of limitation provide the IRS time to review and seek redress for errors in tax returns, whether intentional or not. Under the general rule, the IRS must assess income taxes, estate taxes, and gift taxes within three years from the later of the...

Where wages are paid outside ordinary salary, most employers choose to withhold at an optional flat percentage, instead of using the withholding tables. The current flat rate is 22%. Then again, special rules apply to the extent supplemental wages are...

There are over 100 penalties in the Internal Revenue Code. Learn more about the penalties the IRS asserts most frequently, and that can apply to all types of taxpayers (individuals, corporations, partnerships, trusts and estates, etc.) and all types of...

The Treasury Department recently proposed regulations providing guidance on the ability of taxpayers to transfer by sale certain federal income tax credits derived from investments in renewable energy projects. This article provides an overview of the...

The American Rescue Plan Act of 2021 (also called the COVID-19 Stimulus Package), Pub. L. No. 117-2 , raised the de minimis threshold for Form 1099-K reporting on third party settlement organizations (TPSOs), like PayPal and Venmo, under I.R.C. §...

A real estate investment trust (REIT) is a tax-favored investment vehicle focused exclusively on real estate interests. The Internal Revenue Code strictly regulates REITs to ensure that the form stays true to its mission. So, if a REIT meets all of the...

Closely following the IRS’s announcement of 2024 inflation-adjusted limits for retirement plans ( Notice 2023-75 ), the IRS also has announced its 2024 inflation-adjusted limits for health FSAs, qualified transportation fringes, income tax rates...

The Internal Revenue Service recently announced its 2024 inflation adjustments to many retirement plan limits. For example, the amount individuals can contribute to their 401(k), 403(b), and most 457 plans will increase to $23,000 in 2024, up $500 from...

Corporate income taxes are levied in 44 states with rates ranging from 2.5% in North Carolina to 11.5% in New Jersey. Of the total, 11 states have top rates at or below 5%, four have rates at or above 9%, and 29 states and the District of Columbia have...

The demanding aspect of the U.S. income tax system is that taxable income starts with gross income (in all its forms) unless otherwise excepted. For executives—perquisites can abound. Are they taxable? Free lunch? Not necessarily. Country club membership...

The exit tax implications for certain covered expatriates in choosing to permanently leave the U.S.’s worldwide taxation system are economically unpleasant. The IRC applies an exit tax to the net unrealized gains on the covered expatriate’s...