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  • Article

    IRS Guidance Removes Obstacle To Restructuring Tax-Exempt Organizations

    Under newly issued guidance, the IRS has made it easier for many tax-exempt organizations to restructure. The IRS will now continue to recognize as exempt, those organizations that:
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Partnership Filing Relief

    On April 8, 2020, the IRS released Revenue Procedure 2020-23, which allows certain partnerships to file amended partnership returns and issue amended Schedules K-1 to their partners for taxable years beginning in 2018 and 2019...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Recent Developments in the Tax Shelter Area

    The ongoing enforcement effort against abusive tax shelters has taken several turns in the past few months. Taxpayers and practitioners who have shelter issues need to be aware of a number of recent developments
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The District Of Columbia Proceeds With Proposed Qui Tam Legislation

    More frequently referred to as "whistleblower cases", a number of state governments have adopted a counterpart to the federal False Claim Act (FCA)
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Tax Problems Loom In The College Admissions Scandal

    The criminal charges of more than 50 individuals, including parents and college athletic coaches, arising from an alleged fraudulent scheme to secure choice slots for their children at elite colleges, has rocked the world of college admissions.
    United StatesCriminal Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    DOL Releases 2015 Form 5500 Including New IRS Compliance Questions

    The Department of Labor recently released the 2015 version of the Form 5500, the annual report which must be filed by certain employee benefit plans subject to ERISA.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Supreme Court Ruling On Same-Sex Marriage Impacts Employee Benefit Plan Administration

    As most readers will already be aware, the Supreme Court's recent ruling in Obergefell mandates that same-sex marriage must now be licensed and recognized at the state level.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Businesses And Organizations Seeking Government Assistance In COVID-19 Crisis Should Pay Attention To "Procurement Lobbying" Rules

    Because of the current economic and employment crisis, many businesses and nonprofits are likely to seek government contracts and grants.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Captive Soft Letter

    On March 20, 2020, the IRS sent so-called "soft letters" to taxpayers who disclosed their participation in section 831(b) captive insurance arrangements identified as transactions of interest by Notice 2016-66.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Time For A Tax Treaty Timeout

    With all due respect for persons who are involved in, interested in, or just cognizant of the U.S. tax treaty program — which is one way of referring to the efforts of the Treasury...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Amended MSRB Rules G-37 And G-8 Require Enhanced Disclosure

    The amendments aim to shed additional light on the bond ballot measure activity of dealers and municipal finance professionals to address concerns that dealers are awarded lucrative municipal securities business in return for actively supporting a bond campaign.
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Professional Golfer Sergio Garcia To Owe More Taxes On Endorsement Income

    Professional athletes, including those who are not US residents, can easily get tangled in a web of complex and very technical tax laws.
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Court Rules Unanimously In Church Pension Plan Cases

    Nor does the legal analysis end once a plan has satisfied itself that the church plan exemption properly applies.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Get Ready For The Employment Tax Compliance Surge IRS To Challenge Status Of Independent Contractors

    The federal and state governments are moving on several fronts to counteract what they consider to be a significant contributor to the income tax gap: underreporting of employment taxes.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    TIME SENSITIVE: IRS Offers Voluntary Disclosure Program For Employee Retention Credit Taxpayers

    On December 21, 2023, the Internal Revenue Service ("IRS") announced a much anticipated, and soon to be short lived, voluntary disclosure program for employers who believe they may have erroneously...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    CARES Act Assistance For Nonprofit Employers: Update On Loans To Larger Nonprofits

    On March 27, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act was signed into law.
    United StatesCoronavirus (COVID-19)
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The New Fiduciary Rules: Considerations For Employers

    Broadly speaking, the Final Rules apply to the provision of investment advice to Covered Plans regardless of plan type.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS/DOJ Summons Seeks To Break Singapore Bank Secrecy On Non-Resident's Account

    In late February 2016, the Justice Department filed an action in federal court to compel UBS's branch in Miami to produce bank records of a Singapore account purportedly owned by a taxpayer who lives in China and is under IRS audit.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    More and More Transfer Pricing Enforcement in Store!

    Recognizing the inexorable globalization of business and underscoring the high priority that top management places on international tax compliance, the IRS just announced a realignment of its Large and Mid-Size Business (LMSB) division into a new Large Business and International division (LB&I) [See IRS press release].
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Voluntary Disclosure Window Closing On Bitcoin Users

    On November 30, 2016, a federal court in San Francisco authorized the IRS to issue a "John Doe" summons to Coinbase, Inc., which operates a web-based global convertible digital currency wallet...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered

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