ArticleAn Overview Of Political Advertising Policies For Google, Twitter, And SnapchatLate last year, many social media and internet giants announced plans to overhaul their advertising policies for political content. United StatesMedia, Telecoms, IT, EntertainmentCaplin & Drysdale, Chartered
ArticleSummary Of New York's New Political Disclosure Rules For NonprofitsAll nonprofit entities, other than 501(c)(3) organizations, that are registered with the New York Attorney General's Charities Bureau must file an EDS with the Bureau.United StatesCorporate/Commercial LawCaplin & Drysdale, Chartered
ArticleWhen A Cyberattack Might Be Espionage: DC Circuit Decides In re U.S. Office Of Personnel Management Data Security Breach LitigationThe case has particular relevance in circumstances in which a cyberattack may have been conducted or sponsored by a foreign government.United StatesPrivacyCaplin & Drysdale, Chartered
ArticleC&D TaxAlert - Looking For FBARs In All The Wrong Places? Limited Relief In New Interim GuidanceOn February 26, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) released proposed regulations intended to clarify the filing requirements for FBARs (a/k/a Report of Foreign Bank and Financial Accounts, Form TD F 90-22.1). United StatesTaxCaplin & Drysdale, Chartered
ArticleIRS Issues Proposed Carried Interest RegulationsThe Proposed Regulations are directly relevant to the taxation of investment managers of private equity funds, venture capital funds, hedge funds, and family offices. United StatesTaxCaplin & Drysdale, Chartered
ArticleNew York Adopts Substantial Changes To Laws Regulating NonprofitsOn December 18, 2013, New York Governor Andrew Cuomo signed the Nonprofit Revitalization Act of 2013 into law.United StatesCorporate/Commercial LawCaplin & Drysdale, Chartered
Article"May Day" GRATs: An Excellent Estate Planning OpportunityA confluence of events makes May 2020 a very attractive month for funding grantor retained annuity trusts, better known as "GRATs." United StatesFamily and MatrimonialCaplin & Drysdale, Chartered
ArticleIs An Act /60 Taxpayer Required To Have A Transfer Pricing Study?The IRS does not require any taxpayer to develop a transfer pricing study. United StatesTaxCaplin & Drysdale, Chartered
ArticleStalled Applications For Section 501(c)(3) Status: Is It Time To Sue The IRS?The backlog of unprocessed applications for tax-exempt status has reached an unprecedented level – the IRS website currently states that applications received in April 2012 are, as of August 2013, just being assigned for evaluation. United StatesTaxCaplin & Drysdale, Chartered
ArticleDOJ National Security Division Announces Significant Appointment And Shift On FARA EnforcementU.S. Department of Justice official John C. Demers, who heads the Department's National Security Division, announced yesterday that Brandon Van Grack will now lead the team that enforces the Foreign Agents Registration Act.United StatesGovernment, Public SectorCaplin & Drysdale, Chartered
ArticleThe OECD Unified Approach Marches (Stumbles?) ForwardThe OECD "Unified Approach" is marching – or perhaps stumbling – forward. The OECD Secretariat proposed the Unified Approach in October 2019 to address the tax challenges arising from the digitalization of the economy.United StatesStrategyCaplin & Drysdale, Chartered
ArticleIRS Grants Penalty Relief For Certain 2019 And 2020 ReturnsThe IRS on August 24 released Notice 2022-36, Penalty Relief for Certain Taxpayers Filing Returns for Taxable Years 2019 and 2020 (the "Notice").United StatesTaxCaplin & Drysdale, Chartered
ArticleIRS Releases Final Carried Interest RegulationsThe Final Regulations provide many welcome clarifications to the proposed regulations published on August 14, 2020 United StatesTaxCaplin & Drysdale, Chartered
ArticleWalking Back Errors In Employee Retention Claims Calls For CareOn Dec. 21, the IRS announced a much-anticipated voluntary disclosure program for employers that believe they may have erroneously claimed a pandemic-era employee retention credit, or ERC.United StatesEmployment and HRCaplin & Drysdale, Chartered
ArticleIRS Guidance On Source Of Gain Under Section 937The IRS has issued definitive advice on the sourcing of capital gains to a bona fide resident of Puerto Rico (a "BFR") who own S corporation stock or interests in partnerships.United StatesTaxCaplin & Drysdale, Chartered
ArticlePractical Impact And Longer Term Consequences Of Citizens United v. FECIn an historic Constitutional development, a divided Supreme Court last Thursday invalidated the decades-old federal prohibition against independent expenditures by corporations in federal political campaigns, holding that corporations have the same First Amendment speech rights as individuals. United StatesCorporate/Commercial LawCaplin & Drysdale, Chartered
ArticleIRS Articulates New Standards For Nonprofit WebsitesOn February 20, 2009, the Internal Revenue Service (the "IRS" or "Service") released a Technical Advice Memorandum with serious implications for affiliated nonprofit organizations that engage in political advocacy online. United StatesTaxCaplin & Drysdale, Chartered
ArticleIRS Releases Hospital Report: Response From Capitol HillThe IRS began its Hospital Compliance Project in May 2006 by first selecting 544 nonprofit hospitals through a review of the Forms 990.United StatesTaxCaplin & Drysdale, Chartered
ArticlePillar Two Questions For The US Can Result In Positive AnswersAnalyzing the OECD's Pillar Two proposal that all countries impose a 15% minimum tax on corporate income is like playing a multidimensional chess game. United StatesTaxCaplin & Drysdale, Chartered
ArticleTreasury Issues Final Regulations To Address Use Of U.S. LLCs To Disguise Beneficial OwnershipThe IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by obtaining a U.S. "TIN and in many circumstances, filing annual returns. United StatesTaxCaplin & Drysdale, Chartered