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“New Rules for the Cloud Rush,” Area Development
Area Development
May 7, 2025
“Turnover on Downs: The IRS’s Rejection of NIL Collectives as Tax-Exempt Entities,” Sports Business Journal
Sports Business Journal
May 5, 2025
"The Current State of Equitable Tolling in Getting Past the 90-Day Tax Court Petition Filing Deadline," The Legal Intelligencer
The Legal Intelligencer
April 25, 2025
“AI Addenda—Navigating the Legal Landscape Across the Software Lifecycle,” The Texas Lawbook
The Texas Lawbook
April 21, 2025
"Affordable Care Act Reporting and Compliance for Employers Just Got Easier," HR Daily Advisor
April 10, 2025
"Full-Fledged Distribution in Times of Tariffs," Tax Notes International
Tax Notes International
April 2, 2025
"What You Need to Know: Top 3 Takeaways From Pa.’s 2025-2026 Budget Proposal" The Legal Intelligencer
March 25, 2025
“What's At Stake In Justices' Review Of IRS Debt Offsets,” Law360 Tax Authority
February 19, 2025
“Turnover Is Coming to the Justice Department Tax Division,” Tax Notes
February 18, 2025
"Getting to the Source: Analyzing Recent Sourcing Updates," - PICPA's CPA Now
Sourcing income is a challenging aspect of tax compliance for businesses operating in multiple jurisdictions.
January 2025
Sourcing income is a challenging aspect of tax compliance for businesses operating in multiple jurisdictions. Many states use market-based sourcing, which sources receipts to the location of the business’s customers; some continue to source receipts to the location of income-producing activity. This blog explores recent sourcing updates throughout the country.
"2024 Year in Review: Top State and Local Tax Cases," Tax Notes State
SALT Practice Chair Jennifer Karpchuk, Senior Counsel Thu Lam and Associate Olivia Klein published in Tax Notes State
December 31, 2024
“Top State And Local Tax Cases Of 2024,” Law360 Tax Authority
December 19, 2024
“Ex-IRS Head Rettig Warns of Agency Funding Cut Effects,” Daily Tax Report – Bloomberg Tax
December 19, 2024
“Making Recycling Work: EPR Laws Help Support a More Sustainable Future,” Recycling Today
Senior Counsel James Asali Published in Recycling Magazine
December 12, 2024
"Recent Supreme Court Decisions Will Facilitate Challenges to Tax Guidance," PICPA CPA Now Blog
Special Counsel Mark Lubin Published in the PICPA CPA Now Blog
December 12, 2024
“Easement Bottleneck Confuses Path to Settlement or Litigation,” Bloomberg Tax
Jasen Hanson’s article in Bloomberg Tax discusses the IRS settlement programs for taxpayers with pending conservation easement cases.
December 3, 2024
"IRS Announces Final Regulations Identifying SCE Transactions as Listed Transactions," The Legal Intelligencer
Philadelphia-based Shareholder Kevin Sweeney and Associate Katherine Wheeler Published in The Legal Intelligencer
November 7, 2024
"Tax Treaty Law: IRS Procedural Gaps — No Late Filing if NRAs File Invalid Returns,” Tax Notes
Shareholder Patrick W. Martin and Associate Luz Villegas-Bañuelos Published in Tax Notes
November 4, 2024
"Recent Supreme Court Decisions May Affect Tax Practice," The Legal Intelligencer
Special Counsel Mark Lubin Published in The Legal Intelligencer
October 31, 2024
“Mastering Worker Classification: 7 Essential Tips for Restaurant Owners,” Modern Restaurant Magazine
Atlanta-Based Senior Associate Jerrika Anderson published in Modern Restaurant Magazine
October 11, 2024
"Tax Tides: Navigating Recent SALT Developments," Tax Notes State
SALT Practice Chair Jennifer Karpchuk, Senior Counsel Thu Lam and Associate Olivia Klein published in Tax Notes State
September 23, 2024
"It’s Your Money and You Need It Now: ERC Refund Anyone?," Daily Report
Atlanta-Based Senior Associate Jerrika Anderson published in the Daily Report
September 23, 2024
“Pitfalls under the centralized partnership audit regime,” Accounting Today
Jasen Hanson Published in Accounting Today
August 26, 2024
“Clearing a Path Forward for Advanced Technologies,” Recycling Magazine
Senior Counsel James Asali Published in Recycling Magazine
August 20, 2024
"What To Do If the IRS Denies Your ERC Refund Claim," Forbes
Tom Cullinan Contributes to Forbes
August 6, 2024
"Top Three Tax Takeaways From the 2024 Pennsylvania Budget," The Legal Intelligencer
Jennifer Karpchuk, Thu Lam and Olivia Klein Write For The Legal Intelligencer
August 6, 2024
"The FTC Non-Compete Rule is in Serious Jeopardy," Texas Lawyer
Kellen Scott Discusses Federal Trade Commission’s Non-Compete Clause Rule in Texas Lawyer Article
July 17, 2024
“Here are Ways Restaurants Can Reduce Audit Risk,” QSR Magazine
Jerrika Anderson Published in QSR Magazine
July 10, 2024
"How To Litigate ERC Refund Claims," Forbes
Tom Cullinan, with Chuck Rettig, Contributes to Forbes
July 1, 2024
"IRS Likely To Increase Scrutiny On The Puerto Rico Act 22 Tax Break," Forbes
Tom Cullinan Contributes to Forbes
June 26, 2024
"Avoiding Unexpected Income Recognition from Partnership Disguised Sales and “Mixing Bowl” Transactions," PICPA CPA Now Blog
Mark Lubin Published in PICPA CPA Now Blog
June 26, 2024
"Is Private Placement Life Insurance the Next IRS Tax Enforcement Target?," The Legal Intelligencer
Kevin Sweeney Article Published in The Legal Intelligencer
June 24, 2024
“Minimizing Tax Cost in Shutting Down a Captive Insurance Company,” The Legal Intelligencer
Mark Lubin Published in The Legal Intelligencer
June 11, 2024
"What’s Next for ERC Refund Claims Pending With the IRS?," Forbes
Tom Cullinan Contributes to Forbes "What's Next for ERC Refund Claims Pending With the IRS?"
May 23, 2024
“Self-Directed IRA Investors: Beware the Specter of UBTI,” Tax Notes Federal
Phil Karter's article “Self-Directed IRA Investors: Beware the Specter of UBTI” in Tax Notes Federal
May 6, 2024
“Considerations in Conducting Tax Due Diligence in Business Acquisitions,” The Legal Intelligencer
Mark Lubin's article "Considerations in Conducting Tax Due Diligence in Business Acquisitions,” in The Legal Intelligencer
The Legal Intelligencer
May 1, 2024
Chasing “Commercial Reasonableness” in Contract Wonderland
Lincoln Chen's article on the "Commercial Reasonableness" Standard
April 23, 2024
"Continued Developments in the SALT Cap Workaround”
Thu Lam's article "Continued Developments in the SALT Cap Workaround” in New Jersey Society of Certified Public Accountants Focus Blog
April 10, 2024
“From Prohibition to Profit: The Potential Tax Benefits of Legalizing Marijuana”
Jennifer Karpchuk's article “From Prohibition to Profit: The Potential Tax Benefits of Legalizing Marijuana” in The Legal Intelligencer
The Legal Intelligencer
April 2, 2024
“Due Process Analysis of Proposed Retroactive Changes to the ERC,” Tax Notes Federal
Tom Cullinan, Sam Kuzniewski and Jala White’s recent article, “Due Process Analysis of Proposed Retroactive Changes to the ERC,” in Tax Notes Federal
Tax Notes Federal
March 25, 2024
“A primer on IRS tax avoidance promoter penalties,” Accounting Today
Tom Cullinan and Erin Hines article “A primer on IRS tax avoidance promoter penalties,” in Accounting Today
Accounting Today
March 22, 2024
"Multiple ERC Clocks are Ticking – What To Do Before Time Runs Out", Forbes
Tom Cullinan's article "Multiple ERC Clocks are Ticking – What To Do Before Time Runs Out," in Forbes
Forbes
January 24, 2024
"Tax Treatment of Partnership and Their Partners—Are Rough Times Ahead?,” The Legal Intelligencer
Mark Lubin's article "Tax Treatment of Partnership and Their Partners—Are Rough Times Ahead?,” in The Legal Intelligencer
The Legal Intelligencer
January 16, 2024
“Taxing Times Ahead: Top SALT Cases to Watch in 2024", Tax Notes State
Jennifer Karpchuk, Thu Lam and Olivia Klein’s article, “Taxing Times Ahead: Top SALT Cases to Watch in 2024,” in Tax Notes State
Tax Notes State
January 8, 2024
“The Continued Fight Over Public Law 86-272,” New Jersey Society of Certified Public Accounts Focus Blog
Jennifer Karpchuk’s article, “The Continued Fight Over Public Law 86-272,” in New Jersey Society of Certified Public Accounts Focus Blog
January 8, 2024
“IRS Settlement Initiatives Can Improve Compliance,” Tax Notes Federal
Tom Cullinan's article, “IRS Settlement Initiatives Can Improve Compliance,” in Tax Notes Federal
Tax Notes Federal
January 1, 2024
“Wealthy Targets of IRS Malta Probe Get Letters Walking It Back,” Bloomberg Tax
Tom Cullinan's article, “Wealthy Targets of IRS Malta Probe Get Letters Walking It Back,” in Bloomberg Tax
December 11, 2023
“Now is the Time for Businesses and Their Advisors to Conduct Internal Compliance Reviews of Filed ERCs”
Kevin Sweeney and Olivia Klein's article “Now is the Time for Businesses and Their Advisors to Conduct Internal Compliance Reviews of Filed ERCs” in CPA Now
CPA Now
November 28, 2023
"Employee Retention Credit Notice Likely Lacks the Force of Law"
Leo Unzeitig and Jaime Vasquez's article "Employee Retention Credit Notice Likely Lacks the Force of Law" in Tax Notes
Tax Notes
November 6, 2023
“A Plain-Meaning Analysis of the ERC”
Tom Cullinan and Sam Kuzniewski's article “A Plain-Meaning Analysis of the ERC” in Tax Notes Federal
Tax Notes Federal
November 6, 2023
“Is It Gonna Be Forever, Or Is It Gonna Go Down in Flames?”
Jennifer Karpchuk and Masha Yevzelman’s article, “Is It Gonna Be Forever, Or Is It Gonna Go Down in Flames?” in Tax Notes State
Tax Notes State
November 1, 2023
“Watch for Pitfalls Associated with Business Acquisitions"
Mark Lubin's article “Watch for Pitfalls Associated with Business Acquisitions" in CPA Now
CPA Now
October 18, 2023
"IRS Announces Employee Retention Credit (ERC) Moratorium and Settlement Initiatives”
Kevin Sweeney's article “IRS Announces Employee Retention Credit (ERC) Moratorium and Settlement Initiatives,” in The Legal Intelligencer
The Legal Intelligencer
October 17, 2023
“IRS to List the Monetized Installment Sale — What Now?”
Tom Cullinan, John Kirbo and Erin Hines article “IRS to List the Monetized Installment Sale — What Now?,” in Tax Notes
August 28, 2023
“Crucial wealth preservation strategies for 2023”
Stephen Heymann and Emily Dabney's article “Crucial wealth preservation strategies for 2023,” in Financial Planning
Financial Planning
August 9, 2023
“Some CRATs Are in the Crosshairs, Yet CRTs Remain Viable”
Tom Cullinan, Scot Kirkpatrick, Steve Wyatt, Asher Fried and Emily Dabney's article “Some CRATs Are in the Crosshairs, Yet CRTs Remain Viable,” in Tax Notes Federal and Tax Notes State
Tax Notes Federal and Tax Notes State
August 7, 2023
“Receipts Sourcing: States’ Increasingly Aggressive Positions on Cost of Performance and Market-Based Sourcing”
Jennifer Karpchuk's article “Receipts Sourcing: States’ Increasingly Aggressive Positions on Cost of Performance and Market-Based Sourcing,” in CPA Now
CPA Now
July 26, 2023
“How to face the IRS attacks on Malta pension plans”
Tom Cullinan, Kevin Sweeney and John Kirbo's article, “How to face the IRS attacks on Malta pension plans,” in Accounting Today
Accounting Today
July 25, 2023
“The Case for a Statute of Limitations for Promoter Penalties”
Tom Cullinan's article, “The Case for a Statute of Limitations for Promoter Penalties,” in Tax Notes
Tax Notes
July 13, 2023
“Procedural Challenges to IRS Compliance With the APA and Its Impact on Tax Litigation”
Jeff Luechtefeld’s article, “Procedural Challenges to IRS Compliance With the APA and Its Impact on Tax Litigation,” in the summer issue of Journal of Emerging Issues in Litigation
Journal on Emerging Issues in Litigation
July 5, 2023
"The IRS to Scrutinize ERC Claims: Are Businesses Ready?"
Kevin Sweeney's article, “The IRS to Scrutinize ERC Claims: Are Businesses Ready?” in CPA Now
CPA Now
July 3, 2023
“Investing in Industrial Outdoor Storage?”
Christine Norstadt’s article, “Investing in Industrial Outdoor Storage?” in Business Facilities
Business Facilities
July 1, 2023
“Family Businesses Should Take These Steps to Survive IRS Scrutiny”
Jasen Hanson’s article, “Family Businesses Should Take These Steps to Survive IRS Scrutiny,” in Bloomberg Tax
Bloomberg Tax
July 1, 2023
"Artificial Intelligence for Lawyers: Not Ready for Prime Time”
Phil Karter’s article, “Artificial Intelligence for Lawyers: Not Ready for Prime Time,” in The Legal Intelligencer
The Legal Intelligencer
June 27, 2023
“Pitfalls of Expanding Business Across State Lines”
Mark Lubin and Jennifer Karpchuk’s article, “Pitfalls of Expanding Business Across State Lines” in CPA Now
CPA Now
June 26, 2023
“11 Things to Know About the Proposed Easement Regs"
Erin Hines article, “11 Things to Know About the Proposed Easement Regs” in TaxNotes Federal
TaxNotes Federal
June 12, 2023
“Flexing State Tax Muscle: The Evisceration of Public Law 86-272"
Jennifer Karpchuk’s article, “Flexing State Tax Muscle: The Evisceration of Public Law 86-272” in PICPA’s CPA Now
PICPA CPA Now
June 7, 2023
"There’s Still Time for Businesses to Claim Employee Retention Credits but They Must Be Vigilant”
Article by Kevin Sweeney on “There’s Still Time for Businesses to Claim Employee Retention Credits but They Must Be Vigilant”
The Legal Intelligencer
May 25, 2023
“‘Cost of Performance’ Confusion”
Jennifer Karpchuk’s article, “‘Cost of Performance’ Confusion,” in Tax Notes
Tax Notes
May 15, 2023
"Emerging Issues in Tax Compliance After IRS Funding Increase”
Tom Cullinan and Juan Vasquez, Jr.'s article, "Emerging Issues in Tax Compliance After IRS Funding Increase,” in Tax Notes Federal
Tax Notes
May 8, 2023
"Land Trusts Should Be Aware of Proposed Easements Regulations"
Erin Hines article, “Land Trusts Should Be Aware of Proposed Easements Regulations,” in Bloomberg Tax
Bloomberg Tax
April 21, 2023
"Key Lessons for Associate Success From a Piano Teacher"
Stuart Clements article, “Key Lessons for Associate Success From a Piano Teacher,” in Texas Lawyer
Texas Lawyer
April 19, 2023
"Understanding Termination for Convenience”
Chadd Reynolds article, “Understanding Termination for Convenience," in Construction Business Owner
Construction Business Owner
April 13, 2023
“Pitfalls Associated with Troubled Businesses”
Mark Lubin's article, “Pitfalls Associated with Troubled Businesses,” in PICPA’s CPA Now
PICPA’s CPA Now
April 10, 2023
“Finding Your Obi-Wan: The Importance of Mentorship in Furthering the Young Lawyer's Career”
Phil Karter’s article, “Finding Your Obi-Wan: The Importance of Mentorship in Furthering the Young Lawyer's Career,” in The Legal Intelligencer
The Legal Intelligencer
April 7, 2023
Budget Talk: Top Tax Takeaways From Shapiro and Kenney’s Budget Proposals
Jennifer Karpchuk’s article, “Budget Talk: Top Tax Takeaways From Shapiro and Kenney’s Budget Proposals,” in The Legal Intelligencer
The Legal Intelligencer
April 1, 2023
Avoid the White Flag by Negotiating Surrender Provisions in Commercial Leases
Stephanie Friese’s article, “Avoid the White Flag by Negotiating Surrender Provisions in Commercial Leases,” in the Daily Report
March 2, 2023
Pennsylvania Ruling Can Help Redefine School Funding Formula
Jennifer Karpchuk and Olivia Klein’s column, “Pennsylvania Ruling Can Help Redefine School Funding Formula,” in Bloomberg Tax
Bloomberg Tax
February 26, 2023
Business Development: Strategies to Inspire Trust and Confidence in Key Relationships
Stephanie Friese’s article, “Business Development: Strategies to Inspire Trust and Confidence in Key Relationships,” in the Daily Report
Daily Report
February 22, 2023
Poor Communication Practices Can Endanger Confidentiality Privilege
Mark Lubin and Phil Karter’s article, “Poor Communication Practices Can Endanger Confidentiality Privilege,” in PICPA’s CPA Now
CPA Now, the blog of the Pennsylvania Institute of Certified Public Accountants
February 7, 2023
Being a New Partner: Techniques for Developing a Client Base
Stewart Weintraub's article "Being a New Partner: Techniques for Developing a Client Base" in The Legal Intelligencer
The Legal Intelligencer
February 3, 2023
Texas Lawyer – FTC Proposes Rule Banning Non-Compete Clauses with Workers
Larry Carbo, Kellen Scott, and AJ Foreman discuss the Federal Trade Commission’s proposed rule banning non-compete clauses with workers in Texas Lawyer article
Texas Lawyer
January 12, 2023
"Business Development: Three Strategies More Important Than the Elevator Speech"
Stephanie Friese's article "Business Development: Three Strategies More Important Than the Elevator Speech" in Daily Report
Daily Report
December 22, 2022
“Tax Change for the New Year: Pa. Recognizes Section 1031 Like-Kind Exchanges”
Jennifer Karpchuk’s article, “Tax Change for the New Year: Pa. Recognizes Section 1031 Like-Kind Exchanges” in The Legal Intelligencer
The Legal Intelligencer
December 22, 2022
"2022 The Year in Review – Tax Law"
Renesha Fountain provides the Tax Law update in the Texas Bar Journal’s 2022 The Year in Review December Issue
December 2022
“Year-End Estate and Gift Tax Planning for Tax Professionals”
Scot Kirkpatrick, Stephen Heymann and Jasmin Severino’s article, “Year-End Estate and Gift Tax Planning for Tax Professionals,” in Bloomberg Tax
Bloomberg Tax
December 14, 2022
“The Highs and Lows of SALT in 2022”
Jennifer Karpchuk article on “The Highs and Lows of SALT in 2022”
Tax Notes State
December 12, 2022
“DEI: Not Quite as Easy as 123”
Alissa Gipson article on "DEI: Not Quite as Easy as 123”
Texas Lawyer
December 5, 2022
“All in the Family – Transition Strategies for Family Businesses” in Bloomberg Tax
Scot Kirkpatrick, Stephen Heymann and Jasmin Severino's article on “All in the Family – Transition Strategies for Family Businesses” in Bloomberg Tax
Bloomberg Tax
November 9, 2022
“IRS’ Increased Funding Means More Scrutiny” in Daily Report
Patrick McCann’s article on “IRS’ Increased Funding Means More Scrutiny” in the Daily Report
Daily Report
November 9, 2022
“The Marquis Fiduciary” in Thomson Reuters Estate Planning Journal and Journal of International Taxation (JOIT)
Scot Kirkpatrick and Stephen Heymann's article on “The Marquis Fiduciary” in Thomson Reuters Estate Planning Journal and Journal of International Taxation (JOIT)
Thomson Reuters Estate Planning Journal and Journal of International Taxation (JOIT)
November 2, 2022
"ERC Audits and the IRS’s $80 Billion Cash Infusion" in Tax Notes Federal
Juan F. Vasquez, Jr., Tania Albuja and Victor Viser's article on "ERC Audits and the IRS’s $80 Billion Cash Infusion" in Tax Notes Federal
Tax Notes Federal
November 2, 2022
"What IRS Funding Increase Means for Taxpayers” in Law360
Patrick J. McCann Jr. and Jasen Hanson’s article on “What IRS Funding Increase Means for Taxpayers”
Law360
October 21, 2022
“Qualified Opportunity Zones and Proposed Legislative Changes” in Business Facilities
Katherine Noll's article on “Qualified Opportunity Zones and Proposed Legislative Changes”
Business Facilities
October 1, 2022
“Termination for Convenience” in Construction Executive
Chadd Reynold’s article on “Termination for Convenience”
Construction Executive
September 20, 2022
"Tax Pitfalls Associated with Closely Held Businesses” in Pennsylvania CPA Journal
Mark Lubin's article “Tax Pitfalls Associated with Closely Held Businesses”
Pennsylvania CPA Journal
September 15, 2022
“How to Make It Rain: Feeding and Nurturing the Client Relationship" in Legal Intelligencer
Phil Karter's article “How to Make It Rain: Feeding and Nurturing the Client Relationship”
The Legal Intelligencer
September 8, 2022
“How to Continue Your Business’s Legacy With Advanced Planning” in Bloomberg Tax
Christine Borrett and Ross Holley article on “How to Continue Your Business’s Legacy With Advanced Planning”
Bloomberg Tax
September 8, 2022
"Preparing to navigate IRS appeals: Strategies for tax practitioners” in Accounting Today
Jeffery Luechtefeld’s article “Preparing to navigate IRS appeals: Strategies for tax practitioners”
September 7, 2022
“Pennsylvania Budget’s Eye-Opening Tax Changes (And Omissions)” in Tax Notes
Jennifer Karpchuk article on “Pennsylvania Budget’s Eye-Opening Tax Changes (And Omissions)”
Tax Notes
September 5, 2022
“Investing in Yourself To Stand Out as a Lawyer” in Texas Lawyer
Stuart Clement’s article, “Investing in Yourself To Stand Out as a Lawyer,” published in Texas Lawyer
Texas Lawyer
September 1, 2022
Expedited Challenges to Economic Substance: Erosion of Protections for Taxpayers and Problems for the IRS
Hale Sheppard's article on "Expedited Challenges to Economic Substance: Erosion of Protections for Taxpayers and Problems for the IRS"
September 2022
“Effective Client Communication: Be the Best Lawyer and Make Sure Clients Know It” in Daily Report
Stephanie Friese’s article, “Effective Client Communication: Be the Best Lawyer and Make Sure Clients Know It”
Daily Report
August 10, 2022
“Should More States Jump on Oklahoma’s Full Expensing Bandwagon?” in Bloomberg Tax
Jennifer Karpchuk and Alissa Gipson’s article, “Should More States Jump on Oklahoma’s Full Expensing Bandwagon"
Bloomberg Tax
August 3, 2022
"The Top Three Takeaways from Pa.’s New Corporate Tax Laws” in Legal Intelligencer
Jennifer Karpchuk’s recent SALT article, “The Top Three Takeaways from Pa.’s New Corporate Tax Laws”
The Legal Intelligencer
August 3, 2022
Expatriating Taxpayers and Unfiled Form 8854: Administration Proposes Disparate Treatment Based on Financial Status
Hale E. Sheppard article on Expatriating Taxpayers and Unfiled Form 8854: Administration Proposes Disparate Treatment Based on Financial Status
International Tax Journal
August 2022
Improper IRS Disclosures of Taxpayer Data under Section 6103: Recovering Punitive Damages Despite No Actual Damages
Hale E. Sheppard article on Improper IRS Disclosures of Taxpayer Data under Section 6103: Recovering Punitive Damages Despite No Actual Damages
Journal of Taxation
August 2022
"Uvalde report should be a call to action"
Justice Eva Guzman opinion article on "Uvalde report should be a call to action"
San Antonio Express News
July 22, 2022