JD Supra

Introduction To “Friends Of” Organizations

Under § 170(c) of the Internal Revenue Code of 1986 as amended (the “Code”), a U.S. taxpayer may only claim a deduction on his or her federal income tax return for contributions made to 501(c)(3) ...
JD Supra

Eligibility for Significant Savings From the Sale of Qualified Small Business Stock Under Internal Revenue Code Section 1202

If you own a small business, you may qualify for significant tax savings under section 1202 of the Internal Revenue Code of 1986, as amended (Section 1202). Owners or investors of certain C ...
JD Supra

The Claim-of-Right Doctrine & Section 1341

The U.S. Congress passed the Tax Cuts and Jobs Act (TCJA) in late 2017, substantially overhauling the Internal Revenue Code of 1986. The TCJA highlighted the importance of several often-overlooked ...
JD Supra

Section 643(b) and Trusts

Recently, there seems to be some confusion regarding section 643(b) of the Internal Revenue Code of 1986, as amended (the “Code”), and its application to trusts. Indeed, that provision—particularly to ...
JD Supra

IRS creates a standardized Section 83(b) Election form

On November 7, 2024, the U.S. Internal Revenue Service (the IRS) released Form 15620, 1 which standardizes elections under section 83(b) of the Internal Revenue Code of 1986, as amended (the “Code,” ...
JD Supra

How Now, High Five? IRS Issues Proposed Regulations for the Expanded Definition of “Covered Employee” Under Section 162(m) that Applies Beginning in 2027

Seyfarth Synopsis: On January 16, 2025, the IRS issued proposed regulations under Section 162(m) of the Internal Revenue Code of 1986 (the “Code”), which limit the amount of compensation a publicly ...