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Excise Tax on Executive Compensation for Tax-Exempt Organizations
State Taxation
Historically and still today, the IRS requires that compensation paid to nonprofit executives be reasonable and not…
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When Does 180 Equal Zero?
Federal Taxation
The tax timelines for 1031 exchanges and Qualified Opportunity Zones (QOZ) require investments to be made within 180 days of…
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IRS Issues Notice 2022-53 and Will Waive 50% Excise Tax on Certain Required Minimum Distributions from Retirement Plans in 2021 and 2022
Federal Taxation
On October 7, 2022, the Internal Revenue Service issued Notice 2022-53,[1] which provides much-needed transition relief in…
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The IRS Extends the Transition Period for Enhanced R&D Tax Credit Reporting Requirements
Federal Taxation
On Friday, September 30, the Internal Revenue Service (the “Service”) set forth administrative guidance indicating that…
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IRS Gets a Boost–With Possible Conditions
Federal Taxation
A better, stronger, faster Internal Revenue Service may soon be tracking down more wealthy tax cheats, thanks to the…
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An Insider’s Guide to IRS Examination of Financial Products and Transactions
Federal Taxation
In my prior role, I was involved in numerous examinations of financial products and transactions as a Large Business and…
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How You Can Lose a Passport Due to Tax Debt
Federal Taxation
If you owe enough in delinquent American federal taxes, the U.S. government can take your passport. The IRS certifies…
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Qualified Retirement Plan Design for Closely Held Businesses
Income Taxation
I. INTRODUCTION The primary goal of most employers in establishing any type of retirement savings program is to…
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Testamentary Transfers to Non-Citizen Spouses
Estate Taxation
Transfers between U.S. Citizen Spouses -— The Marital Deduction U.S. citizens may delay the imposition of either the U.S.…
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