When tax-exempt or non-U.S. taxpayers invest in U.S. businesses, unwanted and unintended U.S. tax obligations can follow without careful planning. Blocker corporations have become a common strategy employed...
Obtaining a Phase I environmental site assessment (ESA) is essential to conducting environmental due diligence for commercial real estate transactions. The goal of a Phase I ESA is to evaluate readily...
Artificial intelligence (AI) tools and resources are inundating the news, social media, professional seminars, and inboxes. AI is part of every conversation across industries and professional services...
Do you need guidance in defending against claims brought under the recently overhauled California's Private Attorneys General Act (PAGA)? Read Private Attorneys General Act in California: Defending...
Confidently present your case in chief to the Trademark Trial and Appeal Board (TTAB) with this opening trial brief that an opposer/petitioner (plaintiff) may use in an opposition or cancellation proceeding...
IRS has used FAQs to a greater extent in its efforts to disseminate information more efficiently and clearly when addressing regulatory changes caused by pandemic. With an uptick in FAQ usage and modifications, taxpayer reliance on the FAQs correspondingly increased. To provide guidance and facilitate usage of FAQs, the IRS has stated that taxpayers who underpay their taxes by reasonably relying on an FAQ will have a reasonable cause defense against negligence and accuracy-related penalties. Tax practitioners should note, however, that this guidance does not constitute a release from liability, as the corresponding tax rules will still apply to assess taxpayer liability.
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