Articles

Brief commentary on cases, rulings, notices, and related federal tax guidance as of December 29, 2021. FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit Penalties for FBAR violations can be severe if applied on a per-account basi...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021. U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes The global tax landscape is rapidly changing as countries around th...

Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger Tax free spin-off transact...

A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met, stockholders may be able to...

Introduction Part 1 of this series discussed the proposals adopted by various countries to impose taxes on the digital economy, particularly by taxing various types of digital advertising and other digital services. These taxes allow countries to re...

Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...