Tax Law News and Insights

Recent taxpayer experiences suggest that IRS agents are becoming more aggressive in denying taxpayer claims of research and development tax credits through narrow construction of the so-called "substantially all" test of Code § 41(d)(1)(C) which requires that the research activities constitute "elements of a process of experimentation." Under Treas. Reg....

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On August 5, 2021, U.S. Senate Finance Committee Chair Ron Wyden (D-Ore.) and Senator Sheldon Whitehouse (D-R.I.) introduced legislation that, if enacted, would tax carried interest recipients annually at ordinary interest rates on "deemed compensation" that may exceed the carried interest recipients' actual economic return. The bill, entitled "Ending the...

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In Texas, property owners associations ("Associations") are typically non-profit corporations created under Chapter 22 of the Texas Business Organizations Code. As a result, many Associations want to know if they qualify for certain tax exemptions reserved for non-profit entities, which can be significant over the life of the Association. Texas...

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