Articles

Churches and religious organizations can both qualify as tax-exempt organizations described in Code Section 501(c)(3). In the case of churches, qualification can be achieved more simply than for a non-church. The allure of tax-exempt status can tempt...

Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the enhanced transfer pricing pena...

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Red Flags in the NFT Market While there are many legitimate uses for cryptocurrencies and digital assets, criminals look for ways to exploit new technologies. A g...

US companies often have commercial transactions with their overseas affiliates in the form of financing, supply, manufacturing, services, or other agreements. Each of these common intercompany transactions can be the cause of significant US or foreig...

Cryptocurrencies, digital assets, and blockchain-based technologies seem to show up everywhere. As the market for these products matures, new markets are emerging. Competitors, new entrants, and investors are acquiring the technologies and platforms...

Brief commentary on the recent developments, cases, rulings, notices, and related federal tax guidance. Biden Administration Budget Proposal May Limit Tax-Free Reorganizations for Corporations with Preferred Stock Recent proposals may limit the abi...