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  • Article

    Washington Post Releases Database Of Reported Nonprofit Asset Diversions

    On October 26, the Washington Post released an insightful investigative report on disclosures of exempt organizations with a "significant diversion" of their assets. The report highlights the range of problems, including embezzlement, theft, fraud, and misuse, that can afflict exempt organizations of all types and sizes
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Releases Additional Guidance On Reporting Health Coverage Information

    Employers continue to confront significant challenges in determining and meeting their obligations under the Patient Protection and Affordable Care Act of 2010, as amended.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    "Steering" The Cadillac Tax: An Opportunity For Employers And Other Stakeholders

    The excise tax on high-cost, employer-sponsored health coverage first received considerable attention when the Patient Protection and Affordable Care Act was enacted in 2010.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Tax Court Rules That IRS Lacks Statutory Authority To Assess Penalties For Failure To File Form 5471

    Pursuant to Section 6038(a), taxpayers who have certain interests in foreign corporations during the taxable year are required to file a Form 5471 with their tax return.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Will Continue Captive Insurance And Syndicated Conservation Easement Examinations Despite Covid-19 Pandemic

    In March 2020, the Internal Revenue Service announced the People First Initiative, pausing many compliance actions during the COVID-19 crisis.
    United StatesCoronavirus (COVID-19)
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Governor Inslee's Presidential Campaign Triggers New Risks for Investment Advisers

    Washington Governor Jay Inslee announced late last week that he is running for President, making him the first sitting governor in the 2020 presidential field.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Could The Fugees' Pras Michel Be Charged With A FARA Violation?

    Pras would therefore have been required to register under FARA within 10 days if he was engaged in FARA-registrable activities and he was not eligible for an exemption.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Captive Insurance: New IRS Tax Reporting Regime Potential For Penalties And Examinations

    Each of the insureds, captives, and any material advisors must report the transaction to the IRS, including the IRS Office of Tax Shelter Analysis.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Elizabeth Stevens Weighs In On Potential IRS Changes To APA Applications In Bloomberg Tax

    The IRS's plan to be more selective about which companies apply for advance approval of their transfer pricing transactions could shorten the application process...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Financier Worldwide Indepth Feature: Transfer Pricing 2023

    Clark Armitage and Elizabeth Stevens offer insights in Indepth Feature: Transfer Pricing for the May 2023 issue of Financier Worldwide Magazine.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Launches New "Transfer Pricing Practice" - Pilot Program Will Select Audit Cases for Scrutiny

    The IRS recently announced that it is taking new steps to improve its effectiveness in transfer pricing audits. In a series of speeches, top IRS officials announced the creation of a "Transfer Pricing Practice" within the Large and Mid-Size Business (LMSB) operating division to "strategically and systematically administer transfer pricing issues."
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Releases Draft of Core Form 990 for 2010

    On October 14, the IRS issued, without comment, a draft of the 2010 "core" Form 990, the annual information return required from tax‐exempt organizations with gross receipts over $500,000 or total assets over $1.25 million. The IRS has not yet released drafts of any schedules to the 2010 Form 990.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Niles Elber Comments On Recent IRS Enforcement Efforts

    The IRS is ramping up collections, examinations, and audits of wealthy Americans and their large partnership companies as part of a crackdown that may affect financial advisors' clients.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    New IRS Program For Retroactive Adoption Of 403(b) Plan Documents

    For most employers, the Treasury regulations applicable to 403(b) plans that were finalized in 2007 included a requirement that such plans be maintained pursuant to a written plan document adopted no later than December 31, 2009.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Timely Estate Planning Techniques, Including "May Day" GRATs

    The current financial and political environment creates unique estate planning opportunities. Depressed stock prices and low interest rates
    United StatesFamily and Matrimonial
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Writing An Effective Corporate Political Activity Policy

    Politics is more important to business than ever. Government entities are now reasserting themselves as active market regulators.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Elizabeth Stevens Comments On Increase Staff At The IRS Covering APAs In Bloomberg

    More hiring and putting the Covid-19 pandemic in the rear-view mirror are paying off for the IRS unit that handles companies' advance tax deals on intercompany transactions.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS To Issue Proposed Regulations Identifying Syndicated Conservation Easements As Listed Transactions

    On December 6, 2022, less than a month after its historic loss in the Tax Court in Green Valley Investors LLC v. Commissioner, 159 T.C. 5 (2022), the IRS released Announcement 2022-28...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    New Guidance On Lobbyist Reporting And Termination

    The Clerk of the House and the Secretary of the Senate recently issued additional guidance regarding Lobbying Disclosure Act ("LDA") reporting requirements and the conditions under which a lobbyist's registration may be terminated.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Supreme Court Rules Against North Carolina In Kaestner On State Income Taxation Of Trusts: What Does This Mean For The District Of Columbia, Virginia, And Maryland?

    A landmark Supreme Court decision decided last week calls into question the constitutionality of local (District of Columbia, Maryland, and Virginia) fiduciary income tax regimes.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered

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