On April 29, 2022, the Joint Committee on Taxation published its 35-page report (the "Report") relating to the federal tax treatment of political campaign and lobbying activities of tax-exempt organizations.

Cory Halliburton serves as outside general counsel and business adviser to a nationwide nonprofit / tax-exempt client base, as well as for multi-state professional service companies.

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income.

In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties.

As our previous firm Insights discuss, there is a numbered notice for almost any communication the IRS provides to a taxpayer. See, e.g., CP518 and CP504.

On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

You might receive an IRS Notice CP2000 ("CP2000") in the mail. The IRS issues these particular notices to taxpayers based on discrepancies...

This year has been a banner year for cryptocurrencies, with the prices of Bitcoin and Ethereum reaching all-time highs in November

On December 30, 2022, the Texas Supreme Court issued its opinion in Cameron International Corporation v. Martinez, __ S.W.3d __, 2022 WL __ (Tex. Dec. 30, 2022) (per curiam) ("Cameron").

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

On March 7, 2022, the Financial Crime Enforcement Network ("FinCEN"), a bureau of the U.S. Department of the Treasury alerted financial institutions "to be vigilant against efforts to evade...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting and compliance and anti-deferral regimes such as subpart F, global intangible low taxed income.

If an organization fails to meet either the organizational test or the operational test, the organization is not qualified for tax exemption under section 501(c)(3) of the Code.

The IRS Independent Office of Appeals ("IRS Appeals") was established to provide an "independent" IRS function that is separate and independent from the...