Many employers who filed employee retention tax credit (ERTC) refund claims have been waiting months or even years to receive refund checks. The IRS stopped processing refund claims in mid‑July of 2023 and publicly announced...more
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
10/31/2023
/ Administrative Hearings ,
Corporate Restructuring ,
Franchise Tax Board ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Non-Residents ,
Pass-Through Entities ,
Residency Status ,
S-Corporation ,
Sale of Assets ,
State Taxes ,
Subsidiaries
In a recent memorandum issued by the Office of Chief Counsel, the Internal Revenue Service (IRS) concluded that many "NIL Collectives" may not qualify as tax-exempt under Section 501(c)(3) of the Internal Revenue Code of...more
6/27/2023
/ 501(c)(3) ,
Colleges ,
Fundraisers ,
Internal Revenue Code (IRC) ,
IRS ,
Name and Likeness ,
NCAA ,
Policy Memorandums ,
Student Athletes ,
Tax Exempt Entities ,
Universities
As part of an ongoing effort to modernize its operations and reduce administrative burdens, the Internal Revenue Service (IRS) has revised and updated the Form 8940 for tax-exempt organizations, charities, and nonexempt...more
Facilities owned by nonprofits and government entities are frequently financed with tax-exempt bonds and managed by for-profit management companies. To avoid tainting the tax-exempt status of the interest payable on...more
10/24/2022
/ Compensation Agreements ,
For-Profit Corporations ,
Hotel Management Agreements ,
Hotels ,
Incentive Compensation ,
IRS ,
Management Fees ,
Project Finance ,
REIT ,
Revenue Procedures ,
Safe Harbors ,
Tax Exempt Entities ,
Tax-Exempt Bonds
Every so often something new and different comes along in the world of state and local tax that does not fit within the existing conceptual frameworks and rules. For example, the delivery of digital books and other digital...more
7/27/2022
/ Bitcoin ,
Bitcoin Mining ,
Blockchain ,
Cryptocurrency ,
Digital Marketplace ,
Digital Media ,
Income Taxes ,
Local Taxes ,
Non-Fungible Tokens (NFTs) ,
Popular ,
Property Tax ,
Sales Tax ,
State Taxes ,
Unclaimed Property
A California state appellate court recently upheld the trial court's decision in The 2009 Metropoulos Family Trust v. Franchise Tax Board that nonresident shareholders of an S corporation source gain on the S corporation's...more
6/7/2022
/ Apportionment ,
Asset Purchase Agreements ,
Business Income ,
Family Trusts ,
Franchise Tax Board ,
Goodwill ,
Income Taxes ,
Internal Revenue Code (IRC) ,
S-Corporation ,
Sale of Assets ,
Shareholders ,
State Taxes ,
Subsidiaries ,
Tax Liability
While many businesses have already taken advantage of the opportunities available to them under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and subsequent COVID‑19 relief legislation, there are still...more
While many nonprofits have already taken advantage of the opportunities available to them under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and subsequent COVID-19 relief legislation, there are still...more
Under the CARES Act and subsequent COVID-19 legislation, independent schools may be eligible for the Employee Retention Credit (ERC), a refundable payroll tax credit for employers, including independent schools, whose...more
The Small Business Administration (SBA) is auditing Paycheck Protection Program (PPP) loan forgiveness applications for both First Draw and Second Draw PPP loans, including for nonprofit organizations that received loans. As...more