Podcasts about Internal Revenue Code

In this episode of the Real Estate Pros podcast, host Michelle Kesil welcomes Jeffrey Peterson, a Minnesota attorney and tax law professor specializing in 1031 exchange strategies. Jeffrey explains the intricacies of Section 1031 of the Internal Revenue Code, which allows real estate investors to defer taxes on gains from the sale of appreciated properties by reinvesting in similar properties. He emphasizes the importance of working with qualified intermediaries to navigate the complexities of these exchanges and avoid common pitfalls, such as receiving proceeds before setting up the exchange.   Professional Real Estate Investors - How we can help you: Investor Fuel Mastermind:  Learn more about the Investor Fuel Mastermind, including 100% deal financing, massive discounts from vendors and sponsors you're already using, our world class community of over 150 members, and SO much more here: http://www.investorfuel.com/apply   Investor Machine Marketing Partnership:  Are you looking for consistent, high quality lead generation? Investor Machine is America's #1 lead generation service professional investors. Investor Machine provides true 'white glove' support to help you build the perfect marketing plan, then we'll execute it for you…talking and working together on an ongoing basis to help you hit YOUR goals! Learn more here: http://www.investormachine.com   Coaching with Mike Hambright:  Interested in 1 on 1 coaching with Mike Hambright? Mike coaches entrepreneurs looking to level up, build coaching or service based businesses (Mike runs multiple 7 and 8 figure a year businesses), building a coaching program and more. Learn more here: https://investorfuel.com/coachingwithmike   Attend a Vacation/Mastermind Retreat with Mike Hambright: Interested in joining a "mini-mastermind" with Mike and his private clients on an upcoming "Retreat", either at locations like Cabo San Lucas, Napa, Park City ski trip, Yellowstone, or even at Mike's East Texas "Big H Ranch"? Learn more here: http://www.investorfuel.com/retreat   Property Insurance: Join the largest and most investor friendly property insurance provider in 2 minutes. Free to join, and insure all your flips and rentals within minutes! There is NO easier insurance provider on the planet (turn insurance on or off in 1 minute without talking to anyone!), and there's no 15-30% agent mark up through this platform!  Register here: https://myinvestorinsurance.com/   New Real Estate Investors - How we can work together: Investor Fuel Club (Coaching and Deal Partner Community): Looking to kickstart your real estate investing career? Join our one of a kind Coaching Community, Investor Fuel Club, where you'll get trained by some of the best real estate investors in America, and partner with them on deals! You don't need $ for deals…we'll partner with you and hold your hand along the way! Learn More here: http://www.investorfuel.com/club   —--------------------

    Slam the Gavel podcast welcomes back Mark Andrews. Mark was last on the podcast Season 6, Episode 331. Today we discussed the fraud upon the court, the issues with the alteration of a transcript and how Mark went with other parents, and with Robert Garza on Zoom to discuss with Legislation five bills. Some of the bills were Time Taken, Time Back, Cameras in Court and Parenting Plans and several others.      We also talked about the article written by Laura A. Bischoff, of the Columbus Dispatch: Ohio Supreme Court Suspends judge's law license for steering work to love interest." Change is coming. Change is coming.To Reach Mark Andrews: nottobetakenaway@live.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

    Slam The Gavel welcomes back Marc Fishman to the podcast. Marc was last on Season 6, Episode 343. Today we talked about the 'double standards of justice' and putting 'teeth' into a law questioning the protection of former police officers that have been labeled, 'PATTERN MISCONDUCT,' by the AG in New York.      In April of 2021, Governor Cuomo signed in the Law Enforcement Misconduct Law into the Social Justice Unit of the Attorney General's Office. Since that time 38  officers have been reviewed for misconduct. This law requires that the Police Chief of NY notify the AG when a police officer had had five or more  incidents of reported misconduct. Once the AG is notified, they are supposed to investigate. But the million dollar question is, when will they?To Reach Marc Fishman: protectnewyorkers.com and newrochellepoliceabuse.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

     Slam The Gavel welcomes back Tanith Pereira to the podcast. Tanith is speaking out for the second time as she was last on Season 6, Episode 352. The Estoppel case continues to be dragged out by Judge Michael L. Katz in the State of New York. Tanith discussed how her rights have been violated and has not received Due Process. With a judge dragging his feet, her son is suffering in a fatherless home with a man who isn't even his father.To Reach. Tanith Pereira:  dismantlingfamilycourtcorruption.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

On this episode, we're going back-to-basics to discuss the rules that apply when nonprofits engage in lobbying activities. With legislative sessions ramping-up in several states, it's important to take time to understand the lobbying limits and definitions that apply to your organization's advocacy. But, it's even more important to recognize that public charities can lobby and advocate for or against legislation at the local, state, and federal levels. So, rally your staff and volunteers, and speak up, because your nonprofit can play an important role in impacting public policy.    Attorneys for this Episode  Brittany Leonard   Tim Mooney  Natalie Roetzel Ossenfort    The Importance of Lobbying  Big business often pays for expensive lobbyists to represent their interests in front of legislators, but normal community members cannot foot that bill. Nonprofits who lobby can step up and fill the void.   501(c)(3) public charities can use their experience, funding, and passion for their mission to represent communities by advocating for or against changes to law.   For example, Movement Advancement Project tracked the 2025 spring legislative session and found that every state except for Vermont had an anti-LGBTQ bill proposed but 88% of them did not become law. This was due in part to great nonprofits lobbying against these bills.   How Much Lobbying Can Public Charities Do?  Internal Revenue Code provides two ways for public charities to measure their lobbying limits  Default, Insubstantial Part Test: Public charities can lobby so long as lobbying is an "insubstantial part" of their overall activities (around 3-5% of total activities).  Activities based test, not dollar-based  Broad definitions of lobbying  501(h) Expenditure Test: Most public charities can opt in to using this test to measure their limits (as opposed to the insubstantial part test), and when they do, it provides a mathematical formula to calculate lobbying limits.  Dollar-based test (unpaid, volunteer activities don't count against limits)  Narrower definitions of what qualifies as lobbying  Many organizations can put up to 20% of their budget toward lobbying using the 501(h) election, but the exact amount depends on the organization's annual exempt purpose expenditures.    What is Lobbying?  The definition of lobbying depends on which of the two Internal Revenue Code tests your public charity uses to measure its limits  Insubstantial Part Test: anything that advocates for or against legislation at any level of government is lobbying. For example:  Advocating against a proposed ordinance in your city that would update the housing code in a way that would negatively impact the communities you serve  Supporting a ballot measure that would codify reproductive rights in your state's constitution  Talking to members of Congress to oppose the "Nonprofit Killer" bill  Engaging in advocacy in an attempt to influence what gets included in your state's budget  501(h) Expenditure Test  Direct Lobbying: Communication to a legislator (or their staff) that expresses a view on specific legislation. For example:  Calling your Senator to encourage them to vote for an upcoming bill that will give every family a free puppy  Emailing your State Rep's Chief of Staff to recommend an increase in funding for animal shelter improvements in the state's budget  Grassroots Lobbying: Communicating to the general public your organization's view on specific legislation with a call to action (only four types). For example:  Placing an ad in the newspaper that says "Call your Senator and express your support for legislation that would give every family a free puppy."  Putting a web form on your public charity's website that encourages supporters to input their name and zip code to have a letter in support of a state-level bill automatically sent to their legislators  What about a Threads post encouraging the public to vote in support of a local bond initiative or other ballot measure?  Direct Lobbying. Why? The public is a legislator in the ballot measure process, because the public decides whether the measure passes (and becomes law) or fails (does not become law).   Keep in mind that in addition to counting ballot measure advocacy against your lobbying limits, your ballot measure advocacy may also trigger state or local-level campaign finance reporting (since it happens in the election context).   Examples of activities that do not count as lobbying include education about legislation without expressing a view, advocating for or against executive agency action, for or against executive orders, public education with no call to action under 501h, litigation, etc.  Lobbying definitions can also vary according to state law.  State laws generally don't limit how much lobbying a public charity can do, but they do require lobbyist registration and reporting when certain thresholds are met.  State laws often define lobbying differently from the Internal Revenue Code and can include both legislative and executive branch advocacy activities.    Resources  Being a Player: A Guide to the IRS Lobbying Regulations for Advocacy Charities  Public Charities Can Lobby: Factsheet  State Law Resources: Nonprofit Lobbying Practical Guidance  501(h) Lobbying Limit Calculator 

     Slam The Gavel welcomes back Wren Byrd to the podcast. Wren was last on the podcast Season 5, Episode 213. Today we discussed what has changed in regards to the system and how parents are treated, especially during litigation. We also discussed why there is no enforcement of laws ALREADY in place.     Wren brought up the book, "The Family Law Professional's Field Guide to HIGH CONFLICT LITIGATION; Dynamics, Not Diagnoses by Benjamin D. Garber, PhD, Dana Prescott, JD, LMSW, PhD and Chris Mulchay, PhD. The American Bar Association is endorsing it. Where can this lead while training judges to do the right thing by all families and their children?To Reach Wren Byrd:  info@foundingmoms.orgSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

    Slam the Gavel welcomes back Debbie Carroll to the podcast accompanied by Lindsey Shaffer. Debbie was last on the podcast Season 5, Episodes 167, 180 and 236; Season 6, Episode 327.  Debbie discussed the Memorandum Of Procedure (MOP) and its disgusting implications along with the hard facts of foster care.     Lindsey discussed her history that she and her spouse had a baby girl 5-18-2104, but her spouse decided to move back in with his parents and brothers who were volatile. Lindsey didn't want to live with these brothers and she contacted CPS to see if they could offer other options such as housing. As a result her daughter was removed on 10-16-2015. Trying to find her way through what had unfolded with CPS and a certain caseworker, Lindsey wrote two books,"The Missing," and "Imperium Conflictus." These books can be found on Amazon, Google Play and Pay Hip.To Reach Debbie Carroll: carrolldebbie73@yahoo.com or considerationnonprofit.orgTo Reach Lindsey Shaffer: motivatedirishangel42@yahoo.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

   Slam The Gavel welcomes new guest Tanith Pereira from Manhattan, NY. She has a case suffering in limbo at the hands of Judge Michael L. Katz. Her son was taken away from her when he was just ten years old. The case is five-plus years and going. She only gets to see him every other weekend for just one hour. Her son is suffering from medical and educational neglect.     Tanith is choosing to speak out even though the judge has forbidden her to go on Social Media. But Tanith is speaking out for the sake of her son and her First Amendment Rights.To Reach Tanith Pereira:  dismantlingfamilycourtcorruption.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://youtube.com/@slamthegavelpodcast?si=INW9XaTyprKsaDklhttps://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

     Slam The Gavel welcomes back Justin McPhail to the podcast. He was last on Season 6, Episode 346, talking how "It Wasn't About The Money."      Justin came on the podcast to discuss the Systemic Issues within the Family Court system and how important it is to leave a paper trail. Affidavits were discussed and how import they are to the record. The breaks in Due Process invalidate Family Court proceedings. Justin also discussed more deeply how psychological evaluations and drug tests are illegal and unconstitutional. "Nothing holds true in Family Court, think for yourself, no one else is going to," states Justin.To Reach Justin McPhail:   justinmcphail@att.net  and  SUBSTACK:  @justinmcphail1Supportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://www.youtube.com/@slamthegavelpodcasthostmar5536https://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

    Slam The Gavel welcomes new guest, Latesha Howard to the podcast. Latesha is a mother in San Bernardino CA. She is an advocate for Special Education and has three children of her own. She also has three adopted nieces and nephews that were taken away by CFS (CPS). Latesha is being retaliated on for being an advocate for the children regarding Special Education services. The school staff were annoyed with Latesha for advocating for services for the children and called Children and Family services on her for this reason. With all the stress Latesha has had to endure, she now suffers from Vitiligo.    Latesha has filed a law suit encompassing all individuals involved in the mistreatment of her nieces and nephews. She also has court this Thursday, the 8th of January, 2025.  Will follow this case.To Reach Latesha Howard:  lathow2@yahoo.comSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://www.youtube.com/@slamthegavelpodcasthostmar5536https://substack.com/@maryannpetri?r=kd7n6&utm_medium=iosInstagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetri https://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

     Slam The Gavel podcast welcomes back Todd Humes. He was last on the podcast Season 6, Episode 341. Today Todd gave updates regarding his case involving fraud, no Due Process, and how he has STILL been paying Alimony (while NOT divorced) for the last 5 YEARS at $360.00 per week. Today we discussed the corruption in the Domestic Relations Units and how a second Protection of Abuse Order has been signed with NO EVIDENCE by Judge Kurtz. Todd still hasn't been to court for the divorce to be finalized and his civil suit against his ex-wife and business partner. We also discussed the corrupt lawyers obstructing HIS JUSTICE and the corruption inside the courthouses in Pennsylvania.To Reach Todd Humes:  thumes42@gmail.com(https://www.buymeacoffee.com/maryannpetri)*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

    Slam The Gavel Podcast welcomes back Ellie who was last on the podcast Season 6, Episode 324. Today Ellie discussed updates discussing how her daughter became confused in school and suddenly wanted to be called by a "male" name. An inept caseworker, Attorney Annika Stokes, GAL Michael Horan and Judge Molly Bigelow in Shasta California have an agenda of their own: to put Ellie's daughter in foster care and eventually adopt her out. Ellie still doesn't know if her daughter was given hormones or other psychiatric medications. At present her daughter is residing in foster care, living with five other children and is sharing a room with a male.    Ellie discussed the corruption in the courts and the immigrant component. Ellie and her family came to the U.S. LEGALLY and because of their accent, and culture are being treated like garbage. Her family's Due Process Rights have been violated for so long. Ellie also discussed getting her story out to other media outlets.To Reach Ellie: shastaforart@gmail.com, on X:  https://x.com/Ellieforpa22611, Substack: https://honeybadgerukrainian.substack.com/(https://www.buymeacoffee.com/maryannpetri)*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

Understanding Gross Income: The Foundation of Tax LawThis conversation delves into the intricate world of gross income and its foundational role in tax law. It explores the expansive definition of gross income as outlined in Section 61 of the Internal Revenue Code, the judicial interpretations that have shaped its understanding, and the critical importance of realization in determining taxable income. The discussion also covers common categories of income, statutory exclusions, and the administrative choices made by the IRS that impact taxation. Additionally, it addresses timing rules and the claim of right doctrine, emphasizing the tension between inclusion and exclusion in tax law.In the world of tax law, understanding the concept of gross income is crucial. It's the bedrock upon which the entire tax system is built. This blog post explores the intricacies of gross income, drawing insights from landmark cases and statutory provisions.The Broad Net of Section 61: Section 61 of the Internal Revenue Code casts a wide net, defining gross income as "all income from whatever source derived." This expansive definition ensures that nearly every form of economic gain is captured, from wages and business income to unexpected windfalls.Judicial Interpretation and the Glenshaw Glass Test: The Supreme Court's decision in Commissioner v. Glenshaw Glass established a three-part test for determining income: an undeniable accession to wealth, clearly realized, and under the taxpayer's complete dominion. This test has become a cornerstone of tax law, guiding the inclusion of various forms of income.Navigating Exclusions and Exceptions: While the presumption is that all accessions to wealth are income, there are statutory exclusions, such as gifts and inheritances under Section 102. The Duberstein case highlights the importance of the giver's intent in distinguishing between a gift and compensation.The Role of Realization: Realization is a critical concept in tax law, determining when income is recognized. The Eisner v. McComber case illustrates that mere appreciation in value is not enough; a specific event, like a sale, must occur to trigger taxation.Understanding gross income is essential for navigating the complexities of tax law. By mastering the principles of inclusion, realization, and statutory exclusions, one can effectively analyze and apply tax rules. As the IRS continues to adapt to new economic realities, the definition of gross income will undoubtedly evolve, shaping the future of tax law.Subscribe now to stay updated on the latest insights in tax law and beyond.TakeawaysGross income is the foundation of tax law.The definition of gross income is expansive and includes all accessions to wealth.Judicial interpretations, particularly the Glenshaw Glass case, have shaped the understanding of income.Realization is crucial; income is only taxed when it is realized through a specific event.Gifts and inheritances are excluded from gross income under Section 102.Illegal income is still considered taxable income.The claim of right doctrine allows taxpayers to deduct repayments in the year they occur.Administrative choices by the IRS can lead to non-taxation of certain accessions to wealth.Timing rules are essential for understanding when income is recognized for tax purposes.The tension between inclusion and exclusion reflects the policy goals of the tax system.gross income, tax law, judicial interpretation, Glenshaw Glass, realization, income categories, tax exclusions, administrative choices, timing rules, general welfare exception

Understanding the Intricacies of Tax Law: A Deep DiveThis conversation provides a comprehensive overview of tax law, focusing on the Internal Revenue Code and its structure. It demystifies the complexities of tax law, emphasizing the logical framework that governs it. The discussion covers the role of the IRS, the differences between tax avoidance and evasion, and the intricacies of real estate taxation. Key strategies for navigating tax disputes and understanding tax classifications are explored, along with mechanisms for measuring gain and loss, tax deferral, and depreciation recapture. The conversation concludes with practical advice for law students and practitioners on how to approach tax law effectively.Tax law often conjures images of complex codes and daunting regulations. However, beneath this seemingly impenetrable surface lies a structured and logical system. In this post, we unravel the intricacies of tax law, focusing on its statutory framework and the pivotal role it plays in shaping economic behavior.The Architecture of Tax Law: Tax law is fundamentally statutory, with the Internal Revenue Code serving as its backbone. Unlike other areas of law, where judicial opinions shape the landscape, tax law is primarily driven by Congress. This statutory nature rewards methodical analysis and precise application, making it a unique field within the legal system.The Dual Purpose of Tax Rules: Every tax rule serves two masters: revenue generation and policy implementation. Congress uses the tax code to influence economic behavior, encouraging investments and penalizing certain activities. Understanding this dual purpose is crucial for navigating the complexities of tax law.The Hierarchy of Authority: Navigating tax law requires an understanding of its hierarchy of authority. At the top are the statutes, followed by Treasury regulations, which carry significant weight. Below these are revenue rulings and procedures, which provide guidance but lack the binding authority of regulations.Real Estate and Tax Classification: In real estate, classification is key. The purpose for which a property is held determines its tax treatment, affecting deductions, depreciation, and the character of gains or losses. Mastering these classifications is essential for effective tax planning and compliance.Conclusion: Tax law, often viewed as a burden, is a powerful tool for economic incentives. By understanding its structure and purpose, legal professionals can navigate its complexities and leverage its provisions for strategic advantage. As you delve into the world of tax law, remember that the code is your guide, and methodical application is your ally.Subscribe now to stay updated on the latest insights in tax law and other legal topics.TakeawaysTax law is structured and logical, contrary to common belief.Understanding the hierarchy of tax law is crucial for analysis.The IRS plays a significant role in interpreting tax law.Tax avoidance is legal, while tax evasion is not.Real estate classification is key to tax outcomes.Section 1231 provides beneficial treatment for certain assets.Recognized gain is generally required unless exempted by law.The boot rule affects recognized gain in exchanges.Long-term holding periods can mitigate tax liabilities.Always start tax analysis with the statute itself.tax law, Internal Revenue Code, tax court, IRS, tax avoidance, real estate taxation, tax strategies, depreciation, tax deferral, tax policy

    Slam the Gavel welcomes Heather Bendl and Pete Arnold to the podcast. Heather was last on Season 5, Episode 262. Today Heather is currently juggling  active appeals in both Florida and Illinois, effectively schooling the courts on why they can't just ignore the rulebook, specifically regarding jurisdiction and the UCCJEA. She is challenging a legal nightmare where Florida is trying to enforce a Void Ab Initio Illinois order that was issued without notice and without authority. Heather is asking the higher courts to remind the lower courts that geography and Due Process definitely matter.     Heather's fiancé, Pete Arnold joins her fight as the strategist turning mountains of legal chaos into a clear roadmap for accountability. Together, they aren't just fighting Heather's battle but exposing a systemic crisis where evidence is ignored and parents are silenced. To Reach Heather and Peter:  Non-Profit Email Address: JusticefortheSerlickChildren@gmail.comNon-Profit YouTube Channel:https://www.youtube.com/@JusticefortheSerlickChildrenNon-Profit FB Page:https://www.facebook.com/JusticefortheSerlickChildren(https://www.buymeacoffee.com/maryannpetri)*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

    Slam The Gavel podcast welcomes new guest Justin McPhail. Justin McPhail is a father living in Mississippi and is a business owner. Justin went through a divorce in 2012 and had joint legal custody at that time. However, three years into the case, in April of 2015, He was incarcerated for six years trying to exercise his Constitutional Rights all for being in the arrears $1,400.00, refusing a Drug Test and a Psychological Evaluation.         Simultaneously when Justin was incarcerated, his son had some trouble in school. From there, his 12 year-old son was sent to a juvenile detention center, then to the Alabama Reform School for boys, then sent on to French Camp Academy 2018-2021. Father and son corresponded through mail, then they were able to communicate via phone calls. When his son was 17 years-old, his son was helping his father financially.     Justin states, "the judge knows the truth, but is helping the attorneys hide it, is what is going on."Supportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://www.youtube.com/@slamthegavelpodcasthostmar5536Instagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/aboout*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner shall be held harmless and indemnified from any and all legal liability.Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

Bryan Sajjadi, a Capital Market Strategist at Fidelity Investments, shares how Fidelity's privately owned structure and long-term orientation influence the way investment decisions are made. He outlines how the firm's global research platform—spanning equities, fixed income, sectors, and quantitative analysis—is designed to challenge assumptions, share perspectives, and provide a fuller picture of risk and opportunity across market cycles. Rather than relying on a single style or viewpoint, Sajjadi emphasizes the value of combining multiple disciplines to navigate changing market environments. Sajjadi also discusses how Fidelity blends fundamental research with quantitative tools and emerging technologies to support portfolio decisions and risk awareness. He points to collaboration across asset classes, access to private markets, and long-standing company relationships as inputs that inform—not dictate—investment outcomes. Looking ahead, he frames the market outlook in practical terms, highlighting the need for selectivity, diversification, and flexibility as economic conditions evolve and dispersion across assets increases. Resources: Portfolio Construction | Fidelity Institutional Disclosures: Not FDIC Insured. May Lose Value. No Bank Guarantee. Not NCUA or NCUSIF insured. May lose value. No credit union guarantee. Unless otherwise expressly disclosed to you in writing, the information provided in this material is for educational purposes only. Any viewpoints expressed by Fidelity are not intended to be used as a primary basis for your investment decisions and are based on facts and circumstances at the point in time they are made and are not particular to you. Accordingly, nothing in this material constitutes impartial investment advice or advice in a fiduciary capacity, as defined or under the Employee Retirement Income Security Act of 1974 or the Internal Revenue Code of 1986, both as amended. Fidelity and its representatives may have a conflict of interest in the products or services mentioned in this material because they have a financial interest in the products or services and may receive compensation, directly or indirectly, in connection with the management, distribution, and/or servicing of these products or services, including Fidelity funds, certain third-party funds and products, and certain investment services. Before making any investment decisions, you should take into account all of the particular facts and circumstances of your or your client's individual situation and reach out to an investment professional, if applicable Information provided is general in nature. It is not intended to be, and should not be construed as, legal or tax advice. Fidelity does not provide legal or tax advice. Views expressed are as of the date indicated, based on the information available at that time, and may change based on market and other conditions. Unless otherwise noted, the opinions provided are those of the authors and not necessarily those of Fidelity Investments or its affiliates. Fidelity does not assume any duty to update any of the information. Fidelity Investments is an independent company, unaffiliated with IRIS Media Works, LLC. There is no form of legal partnership, agency affiliation, or similar relationship between IRIS Media Works, LLC. and Fidelity Investments, nor is such a relationship created or implied by the information herein. Fidelity Investments has not been involved with the preparation of the content supplied by IRIS Media Works, LLC. and does not guarantee, or assume any responsibility for, its content. Stock markets, especially foreign markets, are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Although the funds seek to beat the index, this is not guaranteed, and these funds may trail the index. Foreign securities are subject to interest rate, currency exchange rate, economic, and political risks. In general, the bond market, especially foreign markets, are volatile, and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Fixed income securities carry interest rate risk [As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.]. Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. Unlike individual bonds, most bond funds do not have a maturity date, so avoiding losses caused by price volatility by holding them until maturity is not possible. Foreign securities are subject to interest rate, currency exchange rate, economic, and political risks, all of which may be magnified in emerging markets. Digital assets are speculative and highly volatile, and their market movements are very difficult to predict. Investors also face other risks, including significant and negative price swings, flash crashes, and fraud and cybersecurity risks. Digital assets may also be more susceptible to market manipulation than securities. They can become illiquid at any time and are for investors with a high-risk tolerance. Investors in digital assets could lose the entire value of their investment. Investing involves risk, including risk of loss. Investment decisions should be based on an individual's own goals, time horizon, and tolerance for risk. © Morningstar, Inc. All rights reserved. The information contained herein: [1] is proprietary to Morningstar and/or its affiliates; [2] may not be copied or distributed; [3] is not warranted to be accurate, complete, or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. Morningstar is a registered trademark of Morningstar, Inc., and is not affiliated with Fidelity Investments. Fidelity Investments® & Pyramid Design is a registered service mark of FMR, LLC. Third-party trademarks and service marks are the property of their respective owners. All other trademarks and service marks are the property of FMR LLC or an affiliated company. Before investing in any exchange traded fund, have your client consider its investment objectives, risks, charges, and expenses. Contact Fidelity for a prospectus, or a summary prospectus if available, containing this information. Have your client read it carefully. FIDELITY DISTRIBUTORS COMPANY LLC, 900 SALEM STREET, SMITHFIELD, RI 02917 1240462.1.0 Source

    Slam The Gavel welcomes back Investigative Journalist, Richard Luthmann. Richard was last on the podcast Season 5, Episode 228. When he was last on, we discussed Family Court cases and Cancel Culture. Today, we discussed Title IV-E funding and children lost and missing in the foster care system in several states, including the 30 children missing in Minnesota. We also talked about how there are no consequences for false claims.     Richard also brought up the Paul Boyne and the Taran Nolan case and others. Federal Court issues in regards to Rabbi Belinski were explained. We discussed how advocacy and court watching plays a role in family court issues.To Reach Richard Luthmann:  https://linktr.ee/rluthmannSupportshow(https://www.buymeacoffee.com/maryannpetri)Maryann Petri: dismantlingfamilycourtcorruption.comhttps://www.tiktok.com/@maryannpetriFacebook:  https://www.youtube.com/@slamthegavelpodcasthostmar5536Instagram: https://www.instagram.com/guitarpeace/Pinterest: Slam The Gavel Podcast/@guitarpeaceLinkedIn: https://www.linkedin.com/in/maryann-petri-62a46b1ab/  YouTube:  https://www.youtube.com/@slamthegavelpodcasthostmar5536  Twitter https://x.com/PetriMaryannEzlegalsuit.com   https://ko-fi.com/maryannpetrihttps://www.zazzle.com/store/slam_the_gavel/about*DISCLAIMER* The use of this information is at the viewer/user's own risk. Content on this podcast does not constitute legal, financial, medical or any other professional advice. Viewer/user/guest should consult with the relevant professionals. IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or matter addressed herein. Reproduction, distribution, performing, publicly displaying and making a derivative of the work is explicitly prohibited without permission from content creator. The content creator maintains the exclusive copyright and any unauthorized copyright usage is strictly prohibited.  Podcast is protected by owner from duplication, reproduction, distribution, making a derivative of the work or by owner displaying the podcast. Owner to be held harmless and indemnification. Support the showSupportshow(https://www.buymeacoffee.com/maryannpetri)http://www.dismantlingfamilycourtcorruption.com/

There's a nasty little provision in the Internal Revenue Code that incentivizes employers to hire foreign students over American citizens. Senator Cotton of Arkansas has introduced a bill to fix this particular problem, but there are thousands more lurking deep in the Internal Revenue Code. The only real fix? Pass the FAIRtax.

This Day in Legal History: Nevada Admitted as 36th StateOn October 31, 1864, Nevada was officially admitted as the 36th state of the United States, a move driven as much by wartime politics as by the territory's readiness for statehood. With President Abraham Lincoln seeking re-election and needing support for the proposed 13th Amendment to abolish slavery, the Republican-controlled Congress saw strategic value in adding another loyal Union state. Although Nevada's population was below the threshold typically required for statehood, its vast mineral wealth and political alignment with the Union helped accelerate the process. To meet the tight timeline ahead of the 1864 election, Nevada's leaders moved quickly to draft a state constitution.Facing logistical challenges in sending the document from Carson City to Washington, D.C., Nevada officials made the unprecedented decision to transmit the entire text—over 16,000 words—via telegraph. The transmission took over 12 hours and cost more than $4,000, making it the longest and most expensive telegram ever sent at the time. The decision proved effective: the telegram reached the capital in time, and Congress formally approved Nevada's admission on the same day.The speed and cost of Nevada's telegraphic constitution became a symbol of the urgency and improvisation of Civil War-era governance. The state's motto, “Battle Born,” reflects both its literal birth during the Civil War and the political battle over slavery and Union preservation. Nevada's admission also helped secure support for Lincoln's re-election and for the 13th Amendment, which passed Congress in January 1865.In a recently disclosed legal filing, Immigration and Customs Enforcement (ICE) sought taxpayer information on over 1.28 million individuals from the IRS, though only about 47,000 records matched. The request, part of a broader effort to access data on individuals under final removal orders, was submitted under a carve-out in Section 6103 of the Internal Revenue Code, which permits limited disclosures during criminal investigations. The IRS initially rejected ICE's requests citing legal constraints, but a memorandum of understanding in April allowed for limited data sharing. A subsequent refined request from ICE in June targeted a smaller group of 1.27 million, but again, only a small percentage matched IRS records, and many failed to meet legal standards for processing.The case arose from a lawsuit filed by taxpayer advocacy groups and unions, which argue that these disclosures violate the Tax Reform Act, the Privacy Act, and the Administrative Procedure Act. Plaintiffs are seeking a preliminary injunction to halt further sharing. Internal emails reveal IRS officials were concerned about the unprecedented scale and legality of the request, and officials emphasized the need to keep the data sharing confidential. The IRS typically handles about 30,000 such data requests a year, each requiring detailed justification and high-level agency approval. Critics warn that this massive data handover poses urgent threats to taxpayer privacy and due process rights.ICE Sought Records on 1.3 Million Taxpayers, Filing Shows (1)U.S. District Judge Carl Nichols praised two federal prosecutors, Samuel White and Carlos Valdivia, for their handling of a case against Taylor Taranto, despite both being suspended by the Justice Department the day before. The suspension followed their reference to January 6 rioters as “a mob of rioters” and mention of Donald Trump allegedly sharing Barack Obama's address in a sentencing memo. Judge Nichols commended their work as professional and exemplary, stating they upheld the highest prosecutorial standards.Taranto was sentenced to 21 months in prison for firearm and hoax-related charges after being arrested near Obama's D.C. residence in 2023. However, he will not serve additional time due to pretrial detention. Though originally charged for participating in the Capitol riot, those charges were dropped under President Trump's mass clemency order for January 6 defendants issued at the start of his second term. Taranto's defense claimed his statements about explosives were meant as “dark humor” and that he hadn't committed any violence.After White and Valdivia's suspension, a revised sentencing memo—stripped of January 6 and Trump references—was filed by two replacement prosecutors, including a senior DOJ official. The incident reflects broader tensions under the Trump administration, which has repeatedly moved to minimize references to Capitol riot violence and penalize prosecutors involved in politically sensitive cases.US judge praises prosecutors who were suspended after referring to January 6 ‘mob' | ReutersA federal judge allowed the Trump administration to move forward with firing nearly all remaining employees of the Department of Justice's Community Relations Service (CRS), an agency established in the 1960s to mediate racial and ethnic conflicts. U.S. District Judge Indira Talwani, while denying a temporary restraining order sought by civil rights groups, noted that the plaintiffs failed to show immediate, irreparable harm. However, she also stated that the groups are likely to succeed in proving that the executive branch cannot lawfully dissolve a congressionally created agency.The lawsuit, brought by 11 organizations including the NAACP and the Ethical Society of Police, challenges the Justice Department's recent “reduction in force” that would leave just one CRS employee. The move follows a pattern under the Trump administration, which has rejected all new requests for CRS services and proposed no funding for the agency in its budget. Plaintiffs argue that a termination notice stating the layoffs aim to “effectuate the dissolution” of CRS confirms unlawful intent.Although Talwani's ruling allows the firings to proceed, she emphasized that the final outcome may favor the plaintiffs as the case continues. The layoffs coincide with a government shutdown that began October 1, meaning the employees would have been furloughed regardless. The DOJ claims it is merely reorganizing, not eliminating, the agency, though it concedes that only Congress has the authority to formally abolish it.Judge allows Trump administration to fire most of DOJ race-relations agency's employees | ReutersHagens Berman Sobol Shapiro, a prominent plaintiffs' law firm, is under scrutiny in two high-profile class actions, facing judicial criticism and potential sanctions. In Seattle, a federal judge sanctioned the firm for over $223,000 after finding it misled the court and opposing counsel about its client's withdrawal from an antitrust case against Apple and Amazon. The judge said Hagens Berman failed to disclose that their client, who later disappeared from proceedings, had expressed his intent to exit the case months earlier. The firm argues it acted ethically under client confidentiality rules and has asked the judge to revise her dismissal ruling.In a separate matter in Philadelphia, the firm faces possible new sanctions in long-running litigation over thalidomide-related birth defect claims. A special master found misconduct, including altering an expert report and advancing claims lacking legal merit. While Hagens Berman disputes the findings, calling them outside the master's authority and biased, U.S. District Judge Paul Diamond upheld the report. The firm has now requested that Diamond recuse himself, citing an appearance of bias due to his close coordination with the special master.In both cases, Hagens Berman maintains its actions were in good faith and within legal and ethical bounds, while critics and courts point to patterns of misrepresentation and overreach.Law firm Hagens Berman battles sanctions in Apple, thalidomide cases | ReutersThis week's closing theme is by Camille Saint-Saëns.Camille Saint-Saëns was a French composer, organist, conductor, and pianist whose long career spanned the Romantic era and touched the early 20th century. Born in Paris in 1835, he was a child prodigy who began composing at the age of three and gave his first public performance at ten. Saint-Saëns was celebrated for his extraordinary versatility, writing symphonies, concertos, operas, chamber music, and choral works. Though deeply rooted in classical forms, he was an early supporter of contemporary composers like Liszt and Wagner, even as he remained skeptical of more radical modernism. His music often combined technical brilliance with elegance, and his clear, structured style made him a bridge between tradition and innovation. He was also a prolific writer and amateur astronomer, and his intellectual breadth sometimes earned him criticism from those who found his music too refined or academic. Still, Saint-Saëns maintained influence across Europe, and his works remain staples of the concert repertoire.This week's closing theme is Saint-Saëns' Danse Macabre. Originally a song for voice and piano based on a poem by Henri Cazalis, Saint-Saëns later reworked Danse Macabre into a tone poem for orchestra. It depicts Death summoning the dead from their graves at midnight on Halloween for a wild, skeletal waltz. A solo violin—tuned unconventionally to evoke a harsh, eerie sound—plays Death's dance theme, while xylophone rattles mimic clacking bones. The piece was controversial at its premiere in 1875 but quickly became a concert favorite, especially around Halloween. With its vivid orchestration and playful macabre imagery, Danse Macabre is one of classical music's most iconic musical depictions of the supernatural, perfectly capturing the spirit of the season.Without further ado, Saint-Saëns Danse Macabre—enjoy! This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.minimumcomp.com/subscribe

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906. IRS CIRCULAR 230 DISCLOSURE. To ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-aif-on-tax-planning

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906. IRS CIRCULAR 230 DISCLOSURE. To ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-aif-on-tax-planning

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906. IRS CIRCULAR 230 DISCLOSURE To ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-president-of-wealth-management-strategies-discussing-retirement-accumulation-vs-distribution

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906. IRS CIRCULAR 230 DISCLOSURE To ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-president-of-wealth-management-strategies-discussing-retirement-accumulation-vs-distribution

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906.IRS CIRCULAR 230 DISCLOSURETo ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-president-of-wealth-management-strategies-discussing-retirement-income-planning

Mark has been helping individuals retire with confidence for over two decades. He is a passionate professional with a rich history of providing safe growth and advanced income strategies to help make sure his clients have an income they can't outlive. Working with top estate planning attorneys, Mark assists his clients with life insurance and long-term care planning alternatives to ensure legacy preservation for loved ones.Mark has been in the insurance business since 2000 and has held a Series 65 securities license since 1999. In 2018, Mark founded Wealth Management Strategies Financial Services LLC, an investment advisory and retirement solutions firm. Mark is also an Accredited Investment Fiduciary (AIF), which he earned by demonstrating knowledge of ethical behaviors that follow a fiduciary duty to his clients.Mark attended California State University at Northridge with a major in business management and a minor in marketing.Learn more: https://www.wmsretirementsolutions.com/Investments offered through WMS Financial Services LLC, a California registered investment adviser. AKA “WMSFS”. CRD 291291 8820 E. Foxhollow Drive Anaheim, CA 92808. Insurance products and services are offered through Wealth Management Strategies, an affiliated company. Mark D. Turner, Insurance License #0759815 Wealth Management Strategies, 751 S. Weir Canyon Rd. Ste 157-610 Anaheim, CA 92808 (714) 912-4906.IRS CIRCULAR 230 DISCLOSURETo ensure compliance with requirements imposed by the IRS, we inform you that any US federal tax advice contained in this communication is not intended or written to be used and cannot be used for the purpose of (a) avoiding penalties under the Internal Revenue Code or (b) promoting, marketing or recommending to another party any transaction or matter addressed herein.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-mark-turner-president-of-wealth-management-strategies-discussing-retirement-income-planning

In this episode of Voices of Otolaryngology, host Rahul K. Shah, MD, MBA, AAO-HNS EVP and CEO, talks with Matthew D. Scarlett, MD, a private practice otolaryngologist in Charleston, South Carolina, and current Chair of the Academy's ENT Political Action Committee (PAC) Board. Dr. Scarlett breaks down how ENT PAC amplifies the voices of otolaryngologists on Capitol Hill, from securing meetings with lawmakers to advancing bills on prior authorization reform, Medicare reimbursement, and newborn CMV screening. Dr. Scarlett shares his personal journey into advocacy—sparked by frustration with barriers to patient care—and explains how ENT PAC strategically supports bipartisan lawmakers who can make a difference for physicians. The discussion highlights how the PAC Board prioritizes issues, the importance of member participation, and how easy actions like responding to “Act Now” alerts can significantly impact legislative outcomes. Whether you're a seasoned ENT or a trainee new to advocacy, this episode demystifies ENT PAC, encourages engagement, and shows how collective action strengthens the specialty's voice in Washington, DC.  Resources:  AAO-HNS Federal Legislative Advocacy: https://www.entnet.org/advocacy/federal-legislative-advocacy/ Project 535: https://myspecialty.entnet.org/AAOHNS/Project-535/Project-535.aspx Donate to the ENT PAC: https://donation.edonation.com/entpac/website/donate  Note: Contributions to ENT PAC are not deductible as charitable contributions for federal income tax purposes. Contributions are voluntary, and all members of the American Academy of Otolaryngology–Head and Neck Surgery have the right to refuse to contribution without reprisal. Federal law prohibits ENT PAC from accepting contributions from foreign nationals. By law, if your contributions are made using a personal check or credit card, ENT PAC may use your contribution only to support candidates in federal elections. All corporate contributions to ENT PAC will be used for educational and administrative fees of ENT PAC, and other activities permissible under federal law. Federal law requires ENT PAC use its best efforts to collect and report the name, mailing address, occupation, and the name of the employer of individuals whose contributions exceed $200 in a calendar year. ENT PAC is a program of the AAO-HNS which is exempt from federal income tax under section 501 (c) (6) of the Internal Revenue Code.  

In this episode of Voices of Otolaryngology, host Rahul K. Shah, MD, MBA, AAO-HNS/F EVP and CEO, talks with Karen A. Rizzo, MD, a seasoned private practice otolaryngologist and past president of the Pennsylvania Medical Society. Dr. Rizzo, who is also Past Chair of the AAO-HNS Board of Governors, shares her journey from being encouraged by a mentor during residency to representing otolaryngology at the state level and eventually becoming the first otolaryngologist—and only the fifth woman—to lead the nation's oldest state medical society. Dr. Rizzo offers candid insights into why advocacy matters, how to get involved even when it feels intimidating, and the strategies she uses to build relationships with legislators and community leaders. The discussion covers her experiences testifying on scope-of-practice issues, the role of county and state medical societies, and how physicians can start with simple steps like joining local organizations or hosting legislators to make a difference. For otolaryngologists at any career stage, this episode provides an empowering look at how engagement in advocacy not only protects the specialty but also strengthens patient care and professional satisfaction. Resources: AAO-HNS State Legislative Advocacy: https://www.entnet.org/advocacy/state-legislative-advocacy/  Donate to the ENT PAC: https://donation.edonation.com/entpac/website/donate  More Ways to Listen: Spotify: https://open.spotify.com/show/3UeVLtFdLHDnWnULUPoiin Apple Podcasts: https://podcasts.apple.com/us/podcast/voice-of-otolaryngology/id1506655333   Connect the AAO-HNS: Instagram: https://www.instagram.com/aaohns  X (Twitter): https://x.com/AAOHNS  Facebook: https://www.facebook.com/AAOHNS  LinkedIn: https://www.linkedin.com/company/american-academy-of-otolaryngology/  Website: https://www.entnet.org  Shop AAO-HNS Merchandise: https://www.otostore.org  Help Us Improve Future Episodes: Share your feedback and topic suggestions at https://forms.office.com/r/0XpA83XNBQ  Note: Contributions to ENT PAC are not deductible as charitable contributions for federal income tax purposes. Contributions are voluntary, and all members of the American Academy of Otolaryngology–Head and Neck Surgery have the right to refuse to contribution without reprisal. Federal law prohibits ENT PAC from accepting contributions from foreign nationals. By law, if your contributions are made using a personal check or credit card, ENT PAC may use your contribution only to support candidates in federal elections. All corporate contributions to ENT PAC will be used for educational and administrative fees of ENT PAC, and other activities permissible under federal law. Federal law requires ENT PAC use its best efforts to collect and report the name, mailing address, occupation, and the name of the employer of individuals whose contributions exceed $200 in a calendar year. ENT PAC is a program of the AAO-HNS which is exempt from federal income tax under section 501 (c) (6) of the Internal Revenue Code.

The One Big Beautiful Bill Act (OBBBA), signed into law July 4, made the opportunity zone (OZ) incentive a permanent part of the Internal Revenue Code. In this episode of the Tax Credit Tuesday podcast, Michael Novogradac, CPA, and Novogradac partner Jason Watkins, CPA, review the changes to OZs instituted by the OBBBA. They explore the Opportunity Zones (OZ) 2.0 Mapping Tool, which Novogradac launched Aug. 19. Novogradac and Watkins also discuss the emphasis on investing in rural areas for the next set of OZs, nominations which begin July 1, 2026. Finally, the pair the new reporting requirements for OZs and the upcoming "dead zone" for investments, which is projected by some to occur next year.

In this episode of Voices of Otolaryngology, host Dr. Rahul Shah sits down with Douglas D. Backous, MD, neurotologist, Immediate Past President of the AAO-HNS/F, and longtime leader in advancing specialty care. Dr. Backous reflects on his diverse career—from academic medicine and private practice to advocacy and international engagement—and how those experiences shape his vision for the future of otolaryngology. He shares lessons learned from leadership roles, including building bridges between clinicians, policymakers, and industry, and his efforts to improve patient access, workforce development, and innovation adoption. The conversation spans everything from Medicare reimbursement challenges to the importance of social trust, the rise of women in the field, and how the Academy can act as a neutral platform for technological advancement and global collaboration. Listeners will gain valuable perspective on the evolving opportunities and challenges facing otolaryngology, and how the Academy is working to ensure the specialty continues to thrive for both practitioners and patients. Resources: Donate to the ENT PAC: https://donation.edonation.com/entpac/website/donate  Become a Reg-ent Participant: https://www.reg-ent.org  Women in Otolaryngology Section (WIO): https://www.entnet.org/wio/  More Ways to Listen: Spotify: https://open.spotify.com/show/3UeVLtFdLHDnWnULUPoiin Apple Podcasts: https://podcasts.apple.com/us/podcast/voice-of-otolaryngology/id1506655333   Connect to the AAO-HNS: Instagram: https://www.instagram.com/aaohns  X (Twitter): https://x.com/AAOHNS  Facebook: https://www.facebook.com/AAOHNS  LinkedIn: https://www.linkedin.com/company/american-academy-of-otolaryngology/  Website: https://www.entnet.org  Shop AAO-HNS Merchandise: https://www.otostore.org  Help Us Improve Future Episodes: Share your feedback and topic suggestions at https://forms.office.com/r/0XpA83XNBQ  Note: Contributions to ENT PAC are not deductible as charitable contributions for federal income tax purposes. Contributions are voluntary, and all members of the American Academy of Otolaryngology–Head and Neck Surgery have the right to refuse to contribution without reprisal. Federal law prohibits ENT PAC from accepting contributions from foreign nationals. By law, if your contributions are made using a personal check or credit card, ENT PAC may use your contribution only to support candidates in federal elections. All corporate contributions to ENT PAC will be used for educational and administrative fees of ENT PAC, and other activities permissible under federal law. Federal law requires ENT PAC use its best efforts to collect and report the name, mailing address, occupation, and the name of the employer of individuals whose contributions exceed $200 in a calendar year. ENT PAC is a program of the AAO-HNS which is exempt from federal income tax under section 501 (c) (6) of the Internal Revenue Code.

This Day in Legal History: Eisenhower Signs Act Creating NASAOn July 29, 1958, President Dwight D. Eisenhower signed the National Aeronautics and Space Act into law, officially creating NASA. The legislation emerged in response to growing Cold War tensions and the Soviet Union's launch of Sputnik the previous year. It marked a pivotal shift in U.S. federal priorities, establishing a civilian-led space agency to coordinate scientific exploration, aeronautics research, and peaceful uses of space. NASA began operations on October 1, 1958, absorbing the earlier National Advisory Committee for Aeronautics (NACA) and ushering in a new era of government-backed technological ambition.Over the decades, NASA has become a symbol of American innovation, from landing astronauts on the moon to deploying the Hubble Space Telescope. Its work has catalyzed advancements not only in spaceflight, but also in climate science, materials engineering, and telecommunications. The legal framework underpinning NASA reflects a national consensus that science and exploration are critical public goods deserving of federal investment and support.But 67 years later, that consensus is showing strain. Just yesterday, NASA announced that nearly 4,000 employees—about 20% of its workforce—are leaving the agency through the Trump administration's deferred resignation program. This mass exodus follows proposed budget cuts and internal restructuring driven by the Department of Government Efficiency (DOGE), a key player in Trump's effort to slash the federal workforce.The timing couldn't be worse. The administration has called for both sweeping workforce reductions and a significant budget cut of nearly 24% for FY 2026, even as it touts long-term funding increases in the so-called One Big Beautiful Bill Act. Scientists and space advocates, including The Planetary Society, have criticized the inconsistency, calling it a direct threat to American leadership in space. A group of over 300 NASA employees echoed that concern in a public letter this week, denouncing the changes as "rapid and wasteful" and warning that they jeopardize the agency's mission.What began as a proud moment of bipartisan support for science and exploration now faces a political climate where expertise is undervalued and institutional stability is sacrificed for short-term optics.Nearly 4,000 NASA employees opt to leave agency through deferred resignation programIn her latest appeal to the U.S. Supreme Court, Ghislaine Maxwell argues that her 2021 federal sex trafficking conviction should be overturned because it violated a 2007 non-prosecution agreement (NPA) originally struck between Jeffrey Epstein and federal prosecutors in Florida. Maxwell contends that the agreement, which shielded Epstein and his unnamed co-conspirators from federal charges in exchange for his state-level plea, should have also barred her later prosecution in New York. The Justice Department disputes this, saying the NPA applied only to the Southern District of Florida and does not merit Supreme Court review. Maxwell's brief criticizes the DOJ for focusing on Epstein's misconduct rather than the legal scope of the deal, framing the issue as one of government accountability to its promises. The Second Circuit previously upheld her conviction, finding no evidence that the NPA was meant to apply nationally. However, the National Association of Criminal Defense Lawyers filed a brief supporting Maxwell, arguing that even atypical agreements must be honored if made by the government. Political tensions surrounding the Epstein case continue to complicate matters, as Maxwell recently met with Deputy Attorney General Todd Blanche amid renewed scrutiny of the Trump administration's handling of Epstein's prosecution. The Supreme Court is expected to consider whether to hear the case in late September.Ghislaine Maxwell Tells Supreme Court Epstein Deal Shielded HerThe Trump administration has filed a judicial misconduct complaint against Chief U.S. District Judge James Boasberg, accusing him of violating judicial ethics by expressing concerns that the administration might defy court rulings, potentially triggering a constitutional crisis. The complaint centers on comments Boasberg allegedly made during a March meeting of the judiciary's policymaking body, which included Chief Justice John Roberts. The Justice Department argues that these remarks, later echoed in his rulings, undermined judicial impartiality—particularly in a case where Boasberg blocked the deportation of Venezuelan migrants using wartime powers under the Alien Enemies Act. The administration claims Boasberg acted on a political bias when he found probable cause to hold it in criminal contempt for defying his deportation order. The DOJ has asked the D.C. Circuit to reassign the case and refer the complaint to a special investigative panel. Boasberg, appointed to the federal bench by President Obama after an earlier nomination to the D.C. Superior Court by President George W. Bush, has not publicly responded. The D.C. Circuit stayed his contempt finding, and a final ruling is still pending.Trump administration files misconduct complaint against prominent judge Boasberg | ReutersThe U.S. Court of Appeals for the Federal Circuit has extended the suspension of 98-year-old Judge Pauline Newman for another year, citing her continued refusal to undergo a full neuropsychological evaluation to assess her fitness to serve. Despite submitting medical reports from her own experts asserting she is mentally competent, the court concluded that those reports were insufficient and contained inaccuracies, including concerns about memory issues and fainting episodes. Newman's legal team criticized the court's swift decision, arguing that their evidence and arguments were not seriously considered following a recent hearing. Newman, a respected patent law jurist appointed by President Reagan in 1984, is the oldest active federal judge who has not taken senior status and has been a prominent dissenter on the Federal Circuit. The court originally suspended her in 2023 after Chief Judge Kimberly Moore raised concerns about her cognitive and physical condition. Newman sued over the suspension, but her case was dismissed; it is now under review by a separate federal appeals court. The latest ruling reaffirms the court's insistence on comprehensive testing before any reconsideration of her judicial role.US appeals court extends suspension of 98-year-old judge in fitness probe | ReutersDonald Trump has asked a federal court to expedite a deposition of Rupert Murdoch in his $10 billion defamation lawsuit against the Wall Street Journal over a July 17 article linking him to Jeffrey Epstein. The article claimed Trump sent Epstein a 2003 birthday greeting that included a suggestive drawing and cryptic references to shared secrets—allegations Trump calls fabricated. In a court filing, Trump's lawyers said he informed Murdoch before publication that the letter was fake, and Murdoch allegedly responded that he would “take care of it,” which they argue demonstrates actual malice—a necessary legal threshold in defamation cases involving public figures. Trump's team is seeking Murdoch's testimony within 15 days, and Judge Darrin Gayles has ordered Murdoch to respond by August 4. The article's release has intensified political scrutiny of Trump's handling of the Epstein investigation. Legal analysts note Trump faces an uphill battle given the stringent standards for proving defamation, especially against media outlets. Dow Jones, which publishes the Journal, said it stands by its reporting and intends to vigorously defend the case.Trump asks for swift deposition of Murdoch in Epstein defamation case | ReutersMy column for Bloomberg this week argues that the latest shift in federal tax law—the move from the global intangible low-taxed income (GILTI) regime to the net controlled foreign corporation tested income (NCTI) system—should push states to reassess their habitual conformity to the Internal Revenue Code. NCTI expands the scope of taxable foreign income for U.S. multinationals, reflecting a broader federal effort to combat base erosion and bolster global competitiveness. But when states automatically conform to these changes—especially through rolling conformity—they risk inheriting complex, federally motivated rules that don't align with their economic interests or legal authority.Rolling conformity is a mechanism by which a state automatically updates its tax code to reflect changes in the federal Internal Revenue Code as they occur, without requiring separate legislative action. While rolling conformity can reduce administrative friction, it's increasingly problematic in an era of aggressive and frequent federal tax rewrites. States adopting NCTI may find themselves without key federal mechanisms like foreign tax credits or Section 250 deductions, exposing them to potential legal challenges over extraterritorial taxation and apportionment. These lawsuits could be expensive, prolonged, and ultimately hinge on issues that federal tax policy has already moved past. I argue that states need to move beyond passive conformity and take an intentional, sovereign approach to tax policy—reviewing conformity statutes now, decoupling where necessary, and preparing to defend their fiscal independence in the face of Washington's rapid policy swings.Trump Tax Law Should Spur States to Split From Federal ‘Pendulum' This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.minimumcomp.com/subscribe

The best CEOs know how to hold the long-term vision—while building the structure and discipline needed to scale sustainably. That's according to Henry Ward, Founder and CEO of Carta, a networked enterprise resource planning (ERP) platform for private capital markets.In this episode, Henry joins host Rodney Bolden to reflect on his founder journey and the leadership lessons he's learned along the way. They discuss “founder mode,” how the founder mindset evolves as a company grows, and how to manage the tension between innovation and operational rigor within a company. They also cover why more companies are staying private longer and how private companies are offering meaningful equity and liquidity to retain top talent, from early-stage startup to late-stage growth. Follow Invested at Work wherever you listen to or watch podcasts. Visit MorganStanley.com/atwork for more insights on workplace financial benefits. Visit Carta.com to learn more about Henry's work with Carta. Invested at Work is brought to you by Morgan Stanley at Work, hosted by Rodney Bolden. Our executive producers are Fiona Kelsey and Lisa Boyce. Our production partner is Sequel Media Inc. This material is not a solicitation of any offer to buy or sell any security or other financial instrument or to participate in any trading strategy. Guest speakers from outside Morgan Stanley Wealth Management are neither employees of or affiliated with Morgan Stanley Wealth Management. Opinions expressed by such guest speakers are solely their own and do not necessarily reflect those of Morgan Stanley Wealth Management or its affiliates.Morgan Stanley and Carta are not affiliated and this presentation should not be treated as an endorsement of Carta or its products and services. This material may provide the addresses of, or contain hyperlinks to, websites. Morgan Stanley is not implying an affiliation, sponsorship, endorsement with/of the third party or that any monitoring is being done by Morgan Stanley of any information contained within the websites. Except to the extent to which the material refers to website material of Morgan Stanley Wealth Management, the firm has not reviewed the linked site. Equally, except to the extent to which the material refers to website material of Morgan Stanley Wealth Management, the firm takes no responsibility for, and makes no representations or warranties whatsoever as to, the data and information contained therein. Such address or hyperlink (including addresses or hyperlinks to website material of Morgan Stanley Wealth Management) is provided solely for your convenience and information and the content of the linked site does not in any way form part of this document. 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They are often speculative and include a high degree of risk. Investors can lose all or a substantial amount of their investment. They may be highly illiquid with significant lock-up periods and no secondary market, can engage in leverage and other speculative practices that may increase volatility and the risk of loss, and may be subject to large investment minimums. When Morgan Stanley Smith Barney LLC, its affiliates and Morgan Stanley Financial Advisors and Private Wealth Advisors (collectively, “Morgan Stanley”) provide “investment advice” regarding a retirement or welfare benefit plan account, an individual retirement account or a Coverdell education savings account (“Retirement Account”), Morgan Stanley is a “fiduciary” as those terms are defined under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and/or the Internal Revenue Code of 1986 (the “Code”), as applicable. When Morgan Stanley provides investment education, takes orders on an unsolicited basis or otherwise does not provide “investment advice”, Morgan Stanley will not be considered a “fiduciary” under ERISA and/or the Code. For more information regarding Morgan Stanley's role with respect to a Retirement Account, please visit ww.morganstanley.com/disclosures/dol. Tax laws are complex and subject to change. Morgan Stanley does not provide tax or legal advice. Individuals are encouraged to consult their tax and legal advisors (a) before establishing a Retirement Account, and (b) regarding any potential tax, ERISA and related consequences of any investments or other transactions made with respect to a Retirement Account. Morgan Stanley at Work services are provided by wholly owned subsidiaries of Morgan Stanley. Information contained herein is based on data from multiple sources considered to be reliable and Morgan Stanley Smith Barney LLC (“Morgan Stanley”) makes no representation as to the accuracy or completeness of data from sources outside of Morgan Stanley. © 2025 Morgan Stanley Smith Barney LLC. Member SIPC. CRC# 4501001 06/2025

Join Kayla Hicks, MD, and Harry DeCabo, AAO-HNS Director for Advocacy, for an essential discussion on advocacy in otolaryngology, exploring why physician and resident engagement in healthcare policy has never been more critical. This episode breaks down the key legislative priorities affecting otolaryngologists and their patients, with a special emphasis on why residents must be active participants in shaping their professional future. Whether you're a resident feeling unsure about advocacy or an established physician wanting to make a difference, this episode demonstrates how otolaryngologists can effectively bridge clinical expertise with legislative decision-making to ensure policies truly serve patients and physicians alike. Resources: ENT Advocacy Network: https://www.entnet.org/the-ent-advocacy-network/  Project 535: https://www.entnet.org/project535  State Tracker Program: https://www.entnet.org/state-trackers  ENT PAC: https://www.entpac.org  More Ways to Listen: Spotify: https://open.spotify.com/show/3UeVLtFdLHDnWnULUPoiin Apple Podcasts: https://podcasts.apple.com/us/podcast/voice-of-otolaryngology/id1506655333   Connect the AAO-HNS: Instagram: https://www.instagram.com/aaohns  X (Twitter): https://x.com/AAOHNS  Facebook: https://www.facebook.com/AAOHNS  LinkedIn: https://www.linkedin.com/company/american-academy-of-otolaryngology/  Website: https://www.entnet.org  Shop AAO-HNS Merchandise: https://www.otostore.org  Help Us Improve Future Episodes: Share your feedback and topic suggestions at https://forms.office.com/r/0XpA83XNBQ  Subscribe to Voices of Otolaryngology for more insights from leading voices in ENT. New episodes released every Tuesday. Note: Contributions to ENT PAC are not deductible as charitable contributions for federal income tax purposes. Contributions are voluntary, and all members of the American Academy of Otolaryngology–Head and Neck Surgery have the right to refuse to contribution without reprisal. Federal law prohibits ENT PAC from accepting contributions from foreign nationals. By law, if your contributions are made using a personal check or credit card, ENT PAC may use your contribution only to support candidates in federal elections. All corporate contributions to ENT PAC will be used for educational and administrative fees of ENT PAC, and other activities permissible under federal law. Federal law requires ENT PAC use its best efforts to collect and report the name, mailing address, occupation, and the name of the employer of individuals whose contributions exceed $200 in a calendar year. ENT PAC is a program of the AAO-HNS which is exempt from federal income tax under section 501 (c) (6) of the Internal Revenue Code.

In this case, the court considered this issue: Does a proceeding under 26 U-S-C § 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes become moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding?The case was decided on June 12, 2025.The Supreme Court held that the Tax Court lacks jurisdiction under 26 U-S-C §6330 to adjudicate disputes between a taxpayer and the IRS once the IRS is no longer pursuing a levy. Justice Amy Coney Barrett authored the 8-1 majority opinion of the Court.Section 6330 of the Internal Revenue Code grants taxpayers the right to a hearing before the IRS can levy (seize and sell) a taxpayer's property to collect unpaid taxes. At this hearing, a taxpayer can raise issues about the levy, including the existence or amount of the underlying tax liability, and the appeals officer makes a “determination” about whether the levy may proceed. The law then permits review of this “determination” by the Tax Court. The Tax Court's jurisdiction is strictly limited to reviewing the determination whether a levy may go forward, not every dispute considered at the hearing. If there is no longer a proposed or ongoing levy—for example, because the taxpayer's liability has been zeroed out during the pendency of the appeal—there is no determination left to review, and thus, no case or controversy for the Tax Court to resolve under §6330.The reasoning rests on several points: (1) The statutory text and structure focus the collection due process hearing and subsequent Tax Court review on the levy alone; (2) The default rule in tax litigation is that challenges to tax liability must proceed as refund suits after payment, except where specifically authorized exceptions, like the collection due process review, apply; and (3) The statute does not authorize the Tax Court to issue refunds or declaratory judgments unrelated to stopping a levy. Therefore, after the IRS drops the levy because the tax debt has been satisfied, any continuing disputes about liability or overpayment must proceed through a refund suit in district court, not in the Tax Court under §6330.Justice Neil Gorsuch authored a dissenting opinion, arguing that the Tax Court retains jurisdiction over all issues addressed in the IRS's determination—including disputes about underlying tax liability—even after a levy is abandoned, and that stripping jurisdiction in these circumstances creates opportunities for the IRS to evade judicial review and leaves taxpayers without meaningful remedies for erroneous IRS actions.The opinion is presented here in its entirety, but with citations omitted. If you appreciate this episode, please subscribe. Thank you.

Welcome to EO Radio Show – Your Nonprofit Legal Resource. I'm Cynthia Rowland, and this is episode 127 of EO Radio Show. Episode 127 is a "refresh" of our episode 13, first released on August 29th, 2022, which covered record retention policies, document destruction schedules, and why they matter. Many nonprofits today have heightened concerns about legal actions, investigations by the IRS or congressional committees, as well as lawsuits, and are proactively reviewing their document management systems and policies. Regardless of these current concerns, many nonprofit leaders are or should be aware that the IRS Form 990, which is the information return for nonprofit organizations, specifically asks the filing organization if it has a document retention policy. While there is no penalty imposed by the Internal Revenue Code for not having a document retention policy, not only is it good form to be able to indicate "Yes" on Form 990, but also having a formal written retention policy is a best practice. In the original 2022 episode, my former partner, Aviva Gilbert, joined me to provide a real-world perspective on how a document retention policy plays out in practice when a nonprofit faces an investigation or is subject to a document request involving other outside parties. Her comments are as helpful today as they were in 2022. Show Notes: Cynthia Rowland, Podcast Host, Partner, Farella Braun + Martel Aviva Gilbert LinkedIn Bio Farella Nonprofit Educations Series Webinar: Investigations, Audits, Subpoenas, Oh My! IRS Form 990 Farella YouTube podcast channel If you have suggestions for topics you would like us to discuss, please email us at eoradioshow@fbm.com. Additional episodes can be found at EORadioShowByFarella.com. DISCLAIMER: This podcast is for general informational purposes only. It is not intended to be, nor should it be interpreted as, legal advice or opinion.

In this episode of Just Compensation, Megan Monson and Jessica I. Kriegsfeld talk to Anthony O. Pergola, Vice Chair of Lowenstein's Emerging Companies & Venture Capital practice group, about the complexities and challenges of Section 280G, a section of the Internal Revenue Code which can be implicated during company change-of-control transactions. The hosts discuss tips for navigating Section 280G and planning strategies to mitigate adverse tax consequences, emphasizing the importance of early preparation and clear communication throughout the M&A process. Refer to episode "Change of Control: Golden Parachute Rules in the Sale Process" for a more detailed overview of Section280G.  Speakers: Megan Monson, Partner, Executive Compensation, Employment & BenefitsAnthony O. Pergola, Partner, Vice Chair, Emerging Companies & Venture CapitalJessica Kriegsfeld, Associate, Executive Compensation, Employment & Benefits

Explore Sections 2704(a) & (b) and their impact on family-limited partnerships, valuation, and estate planning under Chapter 14. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights, and commentary on subjects that affect the profession and clients. Learn more in this podcast.

How do Sections 2701–2704 impact family wealth planning? Discover key traps, safe harbors, and IRS challenges in this expert ACTEC discussion. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights, and commentary on subjects that affect the profession and clients. Learn more in this podcast.

Today's workplace realities are rewriting the HR playbook. That's according to Johnny C. Taylor, Jr., CEO of SHRM, the Society for Human Resource Management, and their 2025 State of the Workplace report.Johnny shares what the research reveals about employees' expectations and the challenges facing HR decision makers today. Host Rodney Bolden shares findings from Morgan Stanley at Work's own State of the Workplace study, and together they dive into what's driving change in recruitment, benefits, employee experience, leadership development, and the growing role of AI in the future of work and in workplace benefits—all topics we'll explore in more depth on this season of Invested at Work. Follow Invested at Work wherever you listen to or watch podcasts. Visit MorganStanley.com/atwork for more insights on workplace financial benefits. Invested at Work is brought to you by Morgan Stanley at Work, hosted by Rodney Bolden. Our executive producers are Fiona Kelsey and Lisa Boyce. Our production partner is Sequel Media Inc.The guest speaker is neither an employee nor affiliated with Morgan Stanley Smith Barney LLC. Opinions expressed by the guest speaker are solely his or her own and do not necessarily reflect those of Morgan Stanley Smith Barney LLC.The information and data presented may be deemed reliable; however, their accuracy and completeness is not guaranteed by Morgan Stanley and providing you with this information is not to be considered a solicitation on our part with respect to the purchase or sale of any securities, investments, strategies or products that may be mentioned.When Morgan Stanley Smith Barney LLC, its affiliates and Morgan Stanley Financial Advisors and Private Wealth Advisors (collectively, “Morgan Stanley”) provide “investment advice” regarding a retirement or welfare benefit plan account, an individual retirement account or a Coverdell education savings account (“Retirement Account”), Morgan Stanley is a “fiduciary” as those terms are defined under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and/or the Internal Revenue Code of 1986 (the “Code”), as applicable. When Morgan Stanley provides investment education, takes orders on an unsolicited basis or otherwise does not provide “investment advice”, Morgan Stanley will not be considered a “fiduciary” under ERISA and/or the Code. For more information regarding Morgan Stanley's role with respect to a Retirement Account, please visit www.morganstanley.com/disclosures/dol. Tax laws are complex and subject to change. Morgan Stanley does not provide tax or legal advice. Individuals are encouraged to consult their tax and legal advisors (a) before establishing a Retirement Account, and (b) regarding any potential tax, ERISA and related consequences of any investments or other transactions made with respect to a Retirement Account.Artificial intelligence (AI) is subject to limitations, and you should be aware that any output from an AI-supported tool or service made available by the Firm for your use is subject to such limitations, including but not limited to inaccuracy, incompleteness, or embedded bias. You should always verify the results of any AI-generated output.Employee stock plan solutions are offered by E*TRADE Financial Corporate Services, Inc., Solium Capital LLC, Solium Plan Managers LLC and Morgan Stanley Smith Barney LLC (“MSSB”), which are part of Morgan Stanley at Work.Morgan Stanley at Work services and stock plan accounts are provided by wholly owned subsidiaries of Morgan Stanley.Morgan Stanley at Work stock plan accounts were previously referred to as Shareworks, StockPlan Connect or E*TRADE stock plan accounts, as applicable. Equity Edge Online® employee stock plan solutions are offered by E*TRADE Financial Corporate Services, Inc. and are part of Morgan Stanley at Work.In connection with stock plan solutions offered by Morgan Stanley at Work, securities products and services are offered by MSSB, Member SIPC. E*TRADE from Morgan Stanley is a registered trademark of MSSB. All entities are separate but affiliated subsidiaries of Morgan Stanley. The laws, regulations, and rulings addressed by the products, services, and publications offered by Morgan Stanley and its affiliates are subject to various interpretations and frequent change. Morgan Stanley and its affiliates do not warrant these products, services, and publications against different interpretations or subsequent changes of laws, regulations, and rulings. Morgan Stanley and its affiliates do not provide legal, accounting, or tax advice. Always consult your own legal, accounting, and tax advisors.Morgan Stanley is an equal opportunity employer committed to diversifying its workforce (M/F/Disability/Vet).© 2025 Morgan Stanley Smith Barney LLC. Member SIPC.CRC 4395861 04/2025

Understand IRC Chapter 14 rules, Sections 2701–2704, and key estate planning strategies to avoid tax pitfalls in family wealth transfers. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights, and commentary on subjects that affect the profession and clients. Learn more in this podcast.

A houseboat can be a home under the Internal Revenue Code and under Medicaid eligibility rules, but it has no protection under bankruptcy or Texas Medicaid Estate Recovery rules. The various treatment of houseboats under different laws are discussed.

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today I'm joined by David Sacarelos, a principal at Baker Tilly. We do a deep dive into the penalties under the Internal Revenue Code sections that apply to insider transactions involving private foundations. Using a recently issued IRS Chief Counsel memorandum, we look at the circumstances of loans by a private foundation that led to significant penalties for indirect self-dealing and jeopardizing investments. Show Notes: Cynthia Rowland, Podcast Host, Partner, Farella Braun + Martel David M. Sacarelos, CPA, CGMA, Principal, Baker Tilly US, LLP Chief Counsel Memo 202504014 IRS Form 4720   EO Radio Show #117: REFRESH Nonprofit Basics: Insider Transactions and Nonprofits Farella YouTube podcast channel Clarifying Notes: (17:06) The $20,000 maximum first-tier tax imposed on foundation managers is not indexed for inflation. (20:59) Per Rev. Ruling 78-76, a private foundation trustee was determined to have participated in a self-dealing transaction both as a disqualified person and as a foundation manager. Consequently, he was found liable for both the tax imposed on self-dealing under IRC Sec. 4941(a) and the tax imposed on foundation managers under IRC Sec. 4941(a)(2). Depending on the facts and circumstances, it is possible to be taxed both as foundation manager and as a disqualified person. If you have suggestions for topics you would like us to discuss, please email us at eoradioshow@fbm.com. Additional episodes can be found at EORadioShowByFarella.com. DISCLAIMER: This podcast is for general informational purposes only. It is not intended to be, nor should it be interpreted as, legal advice or opinion.

In this episode we pick up some more of what Prosperity Gospel is laying down and apply the sniff test. Our conduit into this sewer pit of blasphemy will be the wonderfully named, Creflo Dollar.There are celebrity cameo guest star appearances from West Georgia College, World Dome, Atlanta, Georgia, 501c Tax Exemption Code as per Title 26 under the Internal Revenue Code of 1986, Michael Smith, Atlanta White Pages, Urban Dictionary, Empowered for Success, The True Source of your Prosperity and Grace for Financial Stewardship, PayPal, YouTube, Gulfstream G650, Mars, Law Based Prayer versus Grace Based Prayer, The Power of Supernatural Living, Prayer Into Communion, Johnny Cochran, Madison Square Gardens, The Great Misunderstanding, Old Testament, New Testament,   #666 #SketchComedy #Sketch #Comedy #Sketch Comedy #Atheist #Science #History #Atheism #Antitheist #ConspiracyTheory #Conspiracy #Conspiracies #Sceptical #Scepticism #Mythology #Religion #Devil #Satan #Satanism #Satanist #Skeptic #Debunk #Illuminati #Podcast #funny #sketch #skit #comedy #parody #satire #comedyshow #comedyskits #HeavyMetal #weird #leftist #SatanIsMySuperhero Send us a text

Deep cuts to the IRS workforce mean the agency might have to rely more heavily on technology to keep up taxpayer services and enforcement. The IRS is set to lose 20,000 workers after the Trump administration's second deferred resignation offer. That's in addition to thousands who have already left or are on administrative leave. Barry Johnson, former IRS chief data and analytics officer, oversaw the rollout of artificial intelligence at the agency before his retirement in January. When he left, he said the IRS was piloting an AI tool to help employees search the Internal Revenue Code. The agency also used AI to improve taxpayer services, such as with chatbots, and to make enforcement more efficient. But the workforce cuts could hinder that progress, Johnson said. "I'm especially concerned with proposed cuts in what we call the field staff, the folks who process tax returns and conduct audits," he said. "Because to the extent that we lose that subject matter expertise, our ability to train and validate AI applications will be diminished." In this episode of Talking Tax, Johnson talks to Bloomberg Tax reporter Erin Schilling about the challenges of relying on technology with a shrunken staff, how the research division uses taxpayer data while upholding confidentiality, and what it means for the agency when top executives leave. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Worried about the penalties of accessing your 401k or IRA funds? Most people don't realize there's a way to grow and compound your retirement savings in a secure, tax-advantaged account—while accessing cash value without penalties. In this episode of Private Banking Strategies Podcast, Vance Lowe and Seth Hicks, Esq., break down the powerful Internal Revenue Code 7702 and … Continue reading Avoid 401k & IRA Penalties: Unlock Tax-Free Growth with IRC 7702 | Episode 111 →

Marcia Wagner is the founder of The Wagner Law Group, one of the nation's largest and most highly regarded law firms specializing in ERISA, employee benefits, and executive compensation, and has practiced employee benefits law for over 38 years. Ms. Wagner is an authority on qualified and non-qualified plans, fiduciary issues, deferred compensation, and welfare benefit arrangements, with experience in plan design and drafting, compliance, tax planning, and consultation on all aspects of ERISA and the Internal Revenue Code. Ms. Wagner also serves as an expert witness in ERISA litigation. Ms. Wagner has recently been appointed to the Board of Directors for the American Benefits Council, as well as a Member to the Board of Governors of the American College of Employee Benefits Counsel. Ms. Wagner has written hundreds of articles and 27 books. She is a highly sought after lecturer, is widely quoted in financial journals and has been a guest on Fox, CNN, Bloomberg, and NBC.In this episode, Eric and Marcia Wagner discuss:Committing to continually enhancing servicesBest practices that benefit professionals must followAdopting investment policy statements and other governance documentsDoing things with integrity and excellenceKey Takeaways:Providers must continually enhance services to meet evolving industry standards, legal requirements, and client expectations. Benefit professionals should follow best practices, such as documenting processes, monitoring fees, evaluating service providers through RFPs and benchmarking, and thoroughly documenting meeting minutes to demonstrate prudent fiduciary processes.Investment policy statements, although not legally mandated, are considered fiduciary best practices for retirement plans and should be treated as plan documents if adopted.Believe in the industry's support for the middle class and social stability, maintaining humanity, generosity, flexibility, enthusiasm, pursuing excellence and integrity, and embracing the notion that everything will work out in the end.“Remember your humanity, and don't let the bastards get you down because you will encounter people who are good. Have a generous heart and just be as flexible as you can be. Be open to things that are new. Be enthusiastic. Try to do what you do with excellence and integrity.” - Marcia WagnerConnect with Marcia Wagner:Website: https://www.wagnerlawgroup.com/attorney/wagner-marcia-s/ LinkedIn: https://www.linkedin.com/in/marciawagner Connect with Eric Dyson: Website: https://90northllc.com/Phone: 940-248-4800Email: contact@90northllc.com LinkedIn: https://www.linkedin.com/in/401kguy/ The information and content of this podcast is general in nature and is provided solely for educational and informational purposes. It is believed to be accurate and reliable as of the posting date but may be subject to change.It is not intended to provide a specific recommendation for any type of product or service discussed in this presentation or to provide any warranties, investment advice, financial advice, tax, plan design or legal advice (unless otherwise specifically indicated). Please consult your own independent advisor as to any investment, tax, or legal statements made.The specific facts and circumstances of all qualified plans can vary and the information contained in this podcast may or may not apply to your individual circumstances or to your plan or client plan-specific circumstances.

FAIRtax Power Radio welcomes an old friend back to the program and he brings a young person with him who is getting his first experience with the income tax.  Let's say he found his first encounter with the Internal Revenue Code a somewhat less than pleasant experience.

In this episode of the IC-DISC Show, I sit down with Brian Schwam to discuss how Interest Charge Domestic International Sales Corporations (IC-DISCs) can help businesses save on taxes. With over 35 years of experience, Brian shares how IC-DISC has evolved since 1972 and why it remains a valuable tool for U.S. exporters. He explains how businesses, particularly in the aerospace industry's Maintenance, Repair, and Overhaul (MRO) sector, can take advantage of this incentive to improve their financial position. We walk through a hypothetical example to illustrate how an exporting business could benefit from IC-DISC. Brian explains how companies involved in manufacturing, repairing, or trading parts can qualify and why many eligible businesses overlook this opportunity. We also discuss the annual MRO conference in Atlanta, where industry professionals gather to share insights and best practices. This event highlights the ongoing impact of IC-DISC within the aerospace sector and beyond. Despite the clear benefits, many businesses hesitate to implement IC-DISC due to a lack of awareness or expertise. Brian talks about how our firm partners with CPA firms to integrate IC-DISCs into existing tax processes, making it easier for businesses to take advantage of these savings. He also highlights the underutilization of IC-DISC and why more companies should consider it as part of their tax strategy. We wrap up by discussing the upcoming MRO America's Conference in Atlanta, where exporting aviation maintenance companies can connect and learn more about IC-DISC applications. Whether you're new to IC-DISC or looking to refine your approach, this conversation provides useful insights for businesses considering this tax-saving opportunity.     SHOW HIGHLIGHTS In this episode, I discuss the intricacies and benefits of Interest Charge Domestic International Sales Corporations (IC-DISC) with tax attorney Brian Schwam, who has over 35 years of experience in the field. We explore the historical context of IC-DISC, including its origins in 1972 and the significant changes it underwent following international scrutiny and U.S. tax reforms, such as the 2003 Bush tax cuts and the 2017 Tax Cuts and Jobs Act. Brian provides insights into how IC-DISC can serve as a valuable tax incentive for U.S. exporters, particularly those in the aerospace industry's Maintenance, Repair, and Overhaul (MRO) sector. Through a detailed hypothetical example, we illustrate how companies can leverage IC-DISC to maximize export profits, highlighting specific benefits for pass-through entities and closely held C corporations. We address common apprehensions businesses face regarding IC-DISC implementation and discuss how collaboration with CPA firms can facilitate a seamless integration into existing tax processes. Despite the clear benefits, IC-DISC remains underutilized, and we emphasize the potential missed opportunities for businesses not taking advantage of this tax-saving strategy. The episode also covers upcoming industry events, such as the annual MRO conference in Atlanta and the ICDISC Alliance Conference, which offer valuable networking and professional growth opportunities.   Contact Details LinkedIn - Brian Schwam (https://www.linkedin.com/in/brian-schwam-b6026a3/) LINKSShow Notes Be a Guest About IC-DISC Alliance About WTP Advisors GUEST Brian SchwamAbout Brian TRANSCRIPT (AI transcript provided as supporting material and may contain errors) Dave: Hey, brian, welcome to the podcast. Brian: Thanks, dave, good to be here. Dave: So where on planet Earth are you calling in from today? It's hard to tell by looking at your background. Brian: Outer space. I am in the sunny South Florida. Dave: Okay. Brian: Breezy, south Florida, okay. Dave: Now are you a native of Florida. Brian: I am not a native of Florida. I spent 50 years of my life in the upper Midwest in Wisconsin. Okay, I had to move to Sunbelt. Dave: Okay, Now were you educated in the Midwest then too. Brian: I was. I'm a proud alum of the University of Wisconsin, both for an undergraduate degree in accounting and also my JD from the law school Okay. Dave: So you've and I take it and I've known you a while, so I think that's been several decades ago that your career was started. Is that about right? Brian: Several would be a good good approximation. Yes, I've been at this for 38 years. I know it doesn't look like it, right, okay? Dave: And so, and how long have you been involved in ICDISC? Then Most of that time 38 years, oh, 38 years in ICDISC. Then most of that time, 38 years, oh, 38 years in the disc, wow, yeah. So how does that do you know? Do you have any way to quantify that? Like how many you know ICDISC returns you've, you know, signed or reviewed or prepared, or Boy, it's a big number, dave. Brian: It's probably five figures. Okay, probably, so you know, somewhere north of 10,000 for sure. Okay, over that time period. Dave: Well, and that is why I'm glad that you are one of the founding members of the IC Disc Alliance with me that when I had a chance to partner up with you and some of your team when we created the IC Disc Alliance, I was really excited because in my book I pretty much knew all the players in the IC Disc space and once the famous Neil Block retired after 50 years to me you were without peer in the IC Disc space. Brian: So I really enjoyed collaborating with you through the years here in the ICDISC space, so I really enjoyed collaborating with you through the years. Dave: Thank, you for that, Dave. I hope to be able to follow Neil into that 50-year stratosphere. Yeah, that's big shoes to follow. So let's just talk a bit about the ICDISC. What the heck is it? Why does everyone use that silly acronym? Brian: Because what it really stands for is a mouthful. Dave: Okay. Brian: Discharged Domestic International Sales Corporation and that is what the ICDISC stands for, short right ICDISC. And I don't know if we'll get into. I'll get into what the IC stands for and everything. But basically this is an export incentive that's been in the Internal Revenue Code since 1972. Okay, in various forms. Initially it was an export incentive that just about any company could use, that was exporting goods that were manufactured, produced, grown or extracted in the US. It came under some fire from our trading partners and in 1984, it was transformed into the ICDISC. It started out just as the DISC in 1972 for the Boston International Sales Corporation and it, like I said, came under scrutiny. Our trading partners said hey, you're a, you can't have an exemption from income because you're not. You know you tax things differently in your country. This flies in the face of the other incentives you give your taxpayers. So they changed it into the ICDIS, which made it into, instead of a permanent tax savings, at least on its face, into a temporary savings where, to the extent a taxpayer saved tax and deferred income from tax, they were required to pay an interest charge to the IRS on that deferred tax. Hence the IC. Dave: Okay, okay. Brian: That rate changes every year. It's based on the one-year average TBLO rate as of September 30th annually. And at the same time they instituted something called the Foreign Sales Corporation, which was widely used by thousands of companies, and that came under attack and eventually became the extraterritorial income exclusion which was immediately attacked and eventually, a couple of years later, it just went away. In the meantime, the disk floundered for quite a number of years. In fact, in the year 2000 there were only 787 disks in existence. Dave: Wow, it seems like a shockingly small number. Brian: Well, the tax laws weren't real conducive to benefiting from the disk at that time. Then, in 2003, the Bush tax cuts brought in the concept of qualified dividend income and it took the disk off of life support and really put it on robust territory for pass-through entities, because they could now, to the extent that they could qualify and we'll get into that, to the extent they could qualify and to the extent that they could benefit it provided a 20% rate benefit between ordinary income and qualified dividend income, so it was a significant savings. Now that's been whittled away over time, where it's been reduced here and there. Various tax law changes and probably the largest or the next biggest reduction came in in 2017 with the Trump tax bill, the Tax Cuts and Jobs Act, which reduced the rate on qualified income on non-qualified income. So it reduced the rate on S-corp income partnership income in an individual's tax return to a 29.6% level, and so now the spread between the qualified dividend rate and the ordinary rate just isn't as great as it used to be. It's approaching 6%. So where it used to be 20, then it went to 15, and now it's 6. But it's still a permanent savings for these past three entities and it's not something that they should ignore, because it can save significant taxes, depending upon the level of export activity. Dave: Okay, and now to be clear, depending on a company-specific fact pattern, that spread could be greater. Right For a pass-through. It could be as high as what like? Brian: 13% or so For a pass-through it could be as high as what like, 13% or so For a pass-through business. Dave: It could be as high as 13.2%, okay, but in general we see that it and it could even be somewhere between that, depending on. Brian: Anywhere in between 5.8 and 13.2. Dave: And our experience has been that most companies tend to gravitate more toward the lower end of the savings than the higher end. Brian: Yes. Dave: Yes, okay. Now what about for a C-Corp? Brian: C-Corp is a different animal. Okay, a C-Corp can't use an disc to pay deductible dividends to its owners if it's a closely held C corp. This is not something that a public company can benefit from. But if a closely held business C corp is paying dividends to its shareholders and would like to be able to deduct those payments, rather than not being able to deduct those payments, using an ICDIS can transform the dividend into a deductible dividend. Now, it doesn't save the shareholders any tax, because they're paying tax on the dividend regardless of where it comes from, but it would eliminate the corporate level tax on the C corporation, so that benefit could be as high as 21%. Dave: Okay. Brian: Okay, another manner in which certain C corporations use the disc is to fund bonuses for shareholders and key employees, and then that saves the shareholders 17% tax the difference between a tax on a wage and a tax on a dividend, qualified dividend. So that's a 17% savings for the shareholder. In that case the C-Corp doesn't save any tax. They're getting a deduction either way wages or commission to the disk. And now that I've mentioned the word commission, that's probably a good segue into how does a disk earn income? Yeah, and what is its income? So most discs are what we call commission discs. They earn a commission when a operating business that's related to that disc makes an export sale of qualified export property. So let's dig down into that first. What's qualified export property? Well, that's property that has been manufactured, produced, grown or extracted in the US. So if I'm manufacturing in Mexico or Canada or China and I'm simply selling what I've made in those other countries, you know the disc is not something that's going to benefit that type of a business. Dave: Okay. Brian: It is there to spur US manufacturing, create US jobs, right in line with the America First proposition that's headlining Washington in 2025. Dave: Okay. Brian: So it should be on safe ground, everything that's going on there. So if a company has property that's been manufactured, produced, grown or extracted in the US and they sell it for export outside the United States and not to a US possession, then that sale can potentially generate an ICDIS commission that would be paid to the ICDIS. And keep in mind this ICDISC is not an entity that the outside world sees or understands or knows about. It's simply an entity that does business, if you will, internally with the operating company, so customers don't know about it. It's really transparent to the world. It's just there to help US exporters save tax. Dave: Okay, it's just there to help US exporters save tax. Okay, and the logistics of it. Like say a company has just for simple math, let's say they have $10 million of export, of qualified export revenue, and the ICDIS commission that's calculated to say 10% of that. Brian: Okay. Dave: So 10% of that would be a million dollars, and so walk me through kind of the that's correct and it accrues the deduction, assuming it's not a cash basis taxpayer. Brian: It accrues that deduction at the end of the year, the DISC accrues the income at the end of the year and then by statute the DISC does not pay income tax. So now we've gotten a deduction on one side, we have non-taxable income on the other side and then when the disc pays a dividend to its owners, that becomes a qualified dividend and is taxed at a lower rate. Dave: Okay, so then, effectively, that million dollars gets reclassified from being taxed at ordinary dividend rates to qualified dividend rates. Brian: From ordinary income rates to qualified dividend rates. Dave: yes, Yep, thank you for that. And where that shows up for a pass-through is going to be on the individual shareholders, k-1, right. That box up near the top that shows ordinary taxable income would basically go down. Let's say there was one shareholder, that number goes down by a million dollars. And then there's a box further down on the K-1 for qualified dividend income and that's where the number's being shifted to right. Brian: Right. Assuming the disc is owned by the operating company, which most of the time it is in the pass-through business context, then the ordinary income gets reduced on the K-1 and the dividend income will increase on the K-1, not necessarily in the same year, but that will be the result over time. Dave: And then that tax savings then will show up on the individual shareholders. 1040, right, because their ordinary income line is a million dollars less. The qualified dividend income line is a million dollars more, and that's where that arbitrage. Brian: They pay less tax if they're getting a distribution from the company to cover their taxes, which is often the case, the company doesn't have to distribute as much cash, therefore increasing the working capital of the business. Dave: Okay, well, thank you. Thank you for that. Now, what I want to drill down into a little more today is looking at the aerospace industry, specifically what's called the MRO space in aerospace. Do you know what MRO stands for? Brian: I believe, I do, I believe maintenance, repair and overhaul. Dave: That's my understanding as well. Brian: That's a significant area in the aviation space. Dave: yes, Okay, and I believe that there's a big conference in Atlanta in April with like something like 17,000 expected attendees. Brian: Yeah, just a small gathering. Dave: A small gathering. Brian: For sure. Yes, that's my understanding as well. In fact, I'll be there. Dave: Yeah, I believe we'll both be there, yeah we'll both be there A few of our colleagues. Brian: Yeah, so it's a one a year significant gathering of companies that operate in this MRO space, supporting airlines and other aviation companies, and basically MRO is important because it keeps planes able to fly. Yeah, and we actually have a booth there. Dave: Yeah, and we actually have a booth there. 1818 BC and it makes it sound like it's a date from a long time ago. But yeah, we'll be there and this will be our first year in attendance or exhibiting. And this has come from, in recent years, I'd say, a big ramp up in the number of MRO companies who we are helping with their IC disk. Is that right? Brian: Yeah, absolutely. In fact, one of the sponsors of the conference was a company I was doing some work with and I asked them if he thought it would be a good idea for us to attend, and it was a resounding absolutely that he thought that we could meet a lot of companies that could benefit from this ICDISC similar to his company. Dave: Okay. What are the elements in the MRO space or the characteristics of the companies that make them a good fit for the ICDISC, because my understanding is it's probably only one out of a hundred of like all the registered corporations in the US are really a fit for the disc. Brian: Yeah, so it takes a specific fact pattern to really benefit. So the companies in the service side of the business so let's say they're carpet cleaners or something to that nature they're not going to be able to benefit from the disk. But let's say it's a repair center and airlines will ship in parts to the repair center because they've worn out and they need it. They need a replacement part so that they can fly this plane. So what happens is maybe the repair center takes their part and repairs it, but they previously repaired another part that's identical and then to the customer and that plane gets back in the air right away. So in that scenario, even though it's a different part that's going back out versus what was coming in, that type of activity qualifies as long as what they're doing qualifies as manufacturing and that repair is occurring in the US. Dave: Okay. Brian: Then that type of a company could definitely benefit Other companies. I don't want to use this term, but it's kind of like horse trading. Sometimes companies will buy a surplus of parts, knowing that eventually they're going to be used by somebody and they hang on to these parts, or they find them from somebody who says I don't want these parts anymore, I haven't been able to sell them. So they take a flyer, they take a risk and they buy these parts and they hang on to them and maybe they sell them at a significant profit and maybe they don't. But there's that space as well that can benefit from the disc, and there's some misconception out there that some of the companies that are similar to what I just described can't benefit from a disc, and so, for example, if parts are obtained outside the US, they stay outside the US. They stay outside the US and they're repaired, recertified and resold. Those aren't going to qualify for the ICBITS. But sometimes parts are acquired outside the US and they're brought into the US, they're repaired, put it back into inventory in the US and then sold for export, and that activity does qualify for the ICs, and so it's very important to know where this refurbishment or remanufacturing is taking place. Dave: Okay and yeah, and there's a US content piece to it, right, like if they buy a part from China and all they do is they just put a little lubricant on it and throw it in a box. Brian: that may not qualify and then they export it. The test is what's the customer's value when that part comes into the US. So if it's a burned out hot engine part, for example, yeah there's no value or very little value and it comes into the US, its customers value is close to zero. It gets repaired, it's going to easily meet the content test and it's easily going to be considered manufactured in the US. It's rare, I think, that we'll find that somebody will buy a new part from outside the US just to inventory it here for export. Dave: Okay, yeah, because there's that it's a 50% US content test, right which? Is also, I think confusing on the surface if you don't really dive down into the rules, right, I mean, the layperson may find it. Brian: How do you know what's 50% US content? Well, the cost of good, I mean. Think of it the other way. The foreign content can't be more than 50%. And the foreign content is the cost, the customs value when it was imported. So if I'm selling something for $100, I imported it for as much as $49.99. That's going to qualify as long as I did something, you know, remanufactured it once it got to the US and once it got to the plus, more often than not, I think the value of those things coming in because they're used and worn and damaged parts, they're going to have a low customs valuation where there'll be no problem meeting that content. Dave: Okay, I can see that. Well, I find and my listeners tell me they really like kind of case studies, little mini of case studies, little mini, you know, client case studies On an anonymous basis. Do you have an example or two of some of the types of companies we've worked with, just to give people a flavor of them and, again, you know, being anonymous to you know? What company it is, but just a sense of like the sense of the size of the company, what the benefit might have been. Brian: The size is sort of across the board, right. So some of them are someone on the smaller side. They might have export sales between $5 and $10 million, and then some of them might have export sales of $100 million. It all depends on the size of their business and the benefits are kind of all over the map. Because we don't just do a simple calculation of the benefits. And the reason we don't is because in this industry what we find is there's a lot of margin variability in the companies that are exporting, and then a transaction-by-transaction analysis of the disk commission is what makes the most sense. That allows us to benefit from the margin variability, allows them to benefit from a higher disk commission and obviously then they're going to save more tax. And in some cases the commission grows by 10x by using the T by T. Sometimes it's two or three x, sometimes it's. You know, I've seen you know where it would have been zero because there was an overall loss in the company, but we were able to get a significant discommission with a T by T approach. So it's hard to pinpoint an exact number, but generally speaking it's 15 to 20, you know the commission ends up being 15 to 20% of sales. And if you look at the statutes, one of the statutes says oh, the commission can be 4% of sales, and another implies that it could be anywhere from 4% to 10%, but we generally see in this industry at least 15% on average. It's significantly higher. Dave: Yeah, and I'd like to drill down into that because I tell, and based on my understanding, we may manage more IC disks than any other organization of the country. I mean we I think our number is somewhere north of 500 companies now that we're helping out, and when I'm having these conversations, you know. So I'm, as you know, I'm more focused on the sales side. You know, and you and your team are more focused kind of on the technical aspect of producing these returns, and what I tell people is that our real value isn't being able to produce an IC disk return. Our value is the incremental benefit that the transaction by transaction calculation yields. That the transaction by transaction calculation yields. Because you know just about any any cpa firm you know most of them their software includes the ic disk return. You know, if they just go do a four percent calculation, it's a, you know, reasonably straightforward calculation. But we find that you know they're capturing only a fraction of the total benefit. Brian: That's true, and while I've seen a good number of interesting looking disc returns, I tend to agree that if you follow the directions, anybody can probably prepare a disc return. We do that as well. That's not where we add the most value. Where we add the most value, adding the value comes in unlocking the highest commission possible so that the tax savings are as great as possible. Yeah, and a lot of businesses that are high margin I'm sorry, low margin high volume businesses. When you look at the disc, on its face it looks like oh, there's not much benefit here, we're only making 2% or 3% of sales on our bottom line. So our disc commission would be 2% or 3% of sales. But, like I said, with the transactional approach, if the commission approach is 15%, well now we've taken the company into a tax loss which could potentially save additional taxes for the owners over and above that 5.8%, because now we're offsetting that loss against other income wages, interest, et cetera and being taxed just on the qualified dividend income of the disc. And so you can't just look at the overall margin or overall profitability of the company and project what that, what it's going to look like, Because they vary all over the place. Dave: Based on this transactional approach, yeah, and I would like to talk a bit about. Oftentimes, when I'm talking to a company that's considering a disk, oftentimes they've never even heard of it. Their CPA firm may not have even mentioned the idea. And they'll say, and they'll ask me hey, does this mean my CPA, you know, screwed up by not telling me about it. In my response, you know I try to be generous and I explain it that, look, you know, in our experience only about one out of 100 companies are a candidate. And so let's just say you have a large local CPA firm and they have 100, you know midsize corporate clients. Statistically we find that only one of them, you know, would be a fit for the disk. And your experience may be a little different, you know, feel free to correct me. And so when you think about it from the CPA's perspective, if there's a special part of the tax code and they only have one client that benefits, it's a difficult economic dynamic for the CPA firm to invest in a whole team and expertise to serve one client, right? Isn't that like part of the challenge that the and I know you've worked at a number of large CPA firms Is my understanding correct? That's part of the problem is just their clientele. There aren't enough of them. That makes it worth doing yeah. Brian: Yeah, I think that's a fair characterization. I might phrase it a little bit differently. I mean, there are thousands of CPA firms and they're all excellent generalists. This is not an area where you can be a generalist. Cpa firms often outsource R&D, tax credit work, cost segregation work. This, to me, falls right in that same category. You don't want to dabble in this, and if you're not sure what you're doing, you can get you and your client in trouble. Have good intentions, but if you don't execute it properly, it can be more of a headache than it's worth. And so, like most people, I think people gravitate towards what they know and understand, and things that they don't know and understand can look and sound scary. Dave: Yeah. Brian: So it's like, oh my God, an IC disc. I've never heard of that. I'm not sure I can bring that to my client because I don't really know what I'm doing. Well, I wish I knew somebody I could call to him. He's not a competitor right who could help me through this and help my client through this, and so that's really one of the reasons why we exist, because, as you stated, you don't want it to be a competitor that you call, and so, because we are so hyper focused on what we do and we don't do the things that I'll call the cpa's generalists, that the generalists do, we're an excellent partner because we're not looking to take away anybody's tax return or any of the other type of work that the CPA might be doing for that client. We just want to play in our space. Dave: Yeah, sometimes I'm sorry. Sometimes you know clients or potential clients will say, yeah, but you know our CPA firm does. You know all of our work. It's a one-stop shop thing and I'm afraid having you do the disc return and then doing the corporate return yeah, but our CPA firm does all of our work, it's a one-stop shop thing and I'm afraid having you do the disc return and then doing the corporate return it's just going to be a nightmare for you all to coordinate your efforts. It just sounds like too much trouble. What would your response be to that? Brian: My response is I work with over 500 companies. Generally we do the disk work for those companies. The regular mainstream CPA does everything else. We coordinate our work with that CPA and it's never a problem. We say, look, we're going to need X number of days to turn this around, so please have a draft of the operating company return by a particular date, and then they work towards that date. They give us the return, we get data from the company and we turn the number around so they can finish their tax return and then we go ahead and finish the disc return and I would say 99.9% of the time it works like we're all part of the same thing. Dave: Yeah, because really the CPA they prepare that final draft corporate return. They then pull two numbers from the disk return that goes into the corporate return and then they're done, basically right. Brian: And they're done and they can go ahead and finish up their disk return, I mean their operating company return and their state returns and everything. And then we just have to get the disc return done. And sometimes you know they file their tax return in april and you know the disc returns aren't due till september. So one might say, oh, you could just sit on them until september. But you know, we try to get them done at the same time. Sure sure Everybody can rest easy. But I mean we think of ourselves as a bolt-on resource to that CPA firm while we're working with that and we work with probably 50 to 75 CPA firms around the country in that role- yeah. It works well. I mean, you can talk to any one of them about what it's like to work with us, and I'm sure you'd get a glowing recommendation for how we work with them and for their clients. Dave: Yeah, no, I'm with you. So, as we're nearing the end here, the other thing that people find interesting you'd mentioned in 2003, there were 700 IC disks under 1,000. Yeah, 787. And then, according, if my recollection is correct, the most recent IRS stats that updated that were published, I think, in 2010. And I believe in 2010, there were like 2000 disks. Brian: Yeah, something like 1926. Okay, To be exact, and that number I'm sure has grown dramatically since then. I would guess there's somewhere between eight and 10,000 disks out there now. Okay, yeah. Dave: Yeah, now what's interesting? This is what people find interesting. I believe there's about 50 million business organization, you know business entities in the country, and so let's just assume that's the number, 50 million. Brian: I mean it's tens of millions. Dave: I'm certain of that. For some reason, I think it's 50 million. Does that sound reasonable? Brian: It does so let's think it's 50 million, does that? Dave: sound reasonable. It does. So let's say it's 50 million and on your average, you know we find around one out of a hundred. You know, maybe one out of 200 companies are fit for the disc. So if we run through the math, you know one percent of 50 million, I believe, is 500, 000. You know approximate companies that we think would benefit from a disc. Yet most recent stats, there's only 2000, you know, and maybe it's 4,000, 6,000, you know. Even, let's say it's 10,000 that exists now. So if you divide 10,000 by 500,000, what is that? Like 2%, I think, of the projected eligible company actually have a disc yeah, and people can't. They always are surprised by that and I usually tell them it might. And tell me if your numbers are consistent. I say about 100. One out of 100 benefit or could benefit. The ones who could benefit 90 percent of them have never heard of the disc, maybe 95%, and the 5% of the 1% who have heard of it, even once they hear about it, they usually haven't implemented it. Brian: Right. Then there's a percent that have implemented it. They're not getting out of it what they can. Dave: Right right. Brian: So it's so. There's a lot of missed opportunities by taxpayers and everyone's always trying to save some taxes. It helps fun, you know. It might help hire another employee might help, you know, if the savings are moderate and it's 50, 6070, 1000 of tax savings that still could pay for an employee to come work at the company. Why do? Dave: you think that utilization is so low? I mean because it'd be shocking if only 2% of the companies who did research and development took advantage of the RMD tax credit. Brian: I think it's just not well known. I mean it's very esoteric, it's been in the tax code for ages and ages and it just doesn't you. You know, there were so many years where it just wasn't relevant when you think that it's not something people think about. And then if you know, if you're a small exporter and you're exporting a half a million dollars a year a million dollars a year unfortunately it probably doesn't benefit you to have a disc and so maybe someone will look at it whether that size and they're like, oh yeah, it doesn't benefit you to have a disk and so maybe someone will look at it whether that size and they're like, oh yeah, it doesn't work. And then they grow and they forget that it might work once they've grown. So once a company hits about three million of export sales really should look at it again, because that's where it starts to have economic relevance that's where it starts to have economic relevance. Dave: Do you think some of it could be that? I mean, in general, public companies don't use disks, right? Brian: They just simply don't. Dave: Okay, and so I've found that oftentimes small to mid-sized privately held companies receive a lot of their sophisticated business knowledge from their Fortune 500 suppliers or clients. You know they'll hear from them about something and you know, like the payroll protection program during COVID, you know I suspect some of those might have heard about that from you know some of their large customers. Maybe that's not a good example, but you know that could be another reason. Right, there's just a dearth of knowledge that the CPAs aren't focused on it because the economics don't make sense. The large sophisticated public suppliers and clients don't use it, so they don't hear about it from them. Right, it's not really in the news, it's just. It just kind of flies below the radar screen, doesn't it? Brian: It definitely does, and that's certainly a reason why it's not as utilized as it probably could be. Dave: Yeah, and it seems like you know most of our, you know virtually all of our clients come as a referral from either an existing client or an advisor who we've worked with other clients you know, like a CPA or attorney or banker. So yeah, it's just a yeah, even though you know the podcast is called the Icy Disc Show. I don't get the sense that I'm ever going to. You know, reach Joe Rogan's audience size. It just seems to kind of fly below the radar screen. Brian: Yeah, and the potential audience is probably a little smaller than Joe's. Dave: Probably Well. So the last thing, the other thing people tell me they're surprised about the first year of the disk return. When they set up a disk is to get everything done. And we tell them the disk return's ready and they say, super good, and e-file it for me, like the CPA does the corporate and personal returns. And what is our response when they tell us to go e-file it for them? Brian: The response is unfortunately, the IRS doesn't provide for e-filing of disk returns and we'll need to send you a paper return. You're going to need to sign it and file it with the IRS and the unfortunate thing there is gosh, I don't know what percent of the time, but it's a growing percentage of the time the IRS loses the return Right and then sends a notice saying, hey, we never filed or whatever. And some of these disk returns are quite large. The fact that they because when you do the transaction by transaction analysis, there's a lot of paper that gets produced and filed and it's shocking to me that the IRS would lose those what they do. Dave: So it's interesting what they do. So it's interesting. I like to say that not only does the ICDISC fly under the radar screen of most everything, it even, in some ways, it's almost like it flies under the radar screen of the IRS itself. Brian: Yeah, and they put some things in place with regard to the ICDISC in 1984 and have never changed it. For example, if you're in the situation where you have to pay interest on deferred tax, which often occurs. First of all, a lot of times taxpayers don't realize it and they don't do it. Secondly, if they do it. It's so antiquated that the instructions to the form where you calculate the interest it says please staple a check to this form and mail it in. I mean, who does that in 2020, right? Nobody. People, businesses prefer to do things electronically to avoid checks being stolen, fraudulent activity, so on and so forth. But here the IRS is saying staple a check to this form and mail it to Kansas City, missouri. Dave: Yeah, and I guess it kind of makes sense that you know if there's only a few thousand of these disks in existence. In the same way, you can't expect the CPA firms to make it a heavy focus, I suppose even the IRS. You know there's a hundred other tax incentives or a thousand other tax incentives that are more highly utilized that you know they maybe are spending their time on. Brian: Yeah, as I like to say, the people at the IRS that understood the disc were working there in the 70s and 80s, OK, and they're long retired. Yeah, and they're long retired. There's really not a lot of bodies at the IRS that understand the DISC and certainly when you're doing a transaction by transaction study and calculating the commission on each individual transaction, there's nobody there that understands that. Dave: Nobody Well, and it's kind of the same thing outside the IRS, right? Nobody Well, and it's kind of the same thing outside the IRS, right? I mean I have this joke that nobody makes partner at a big four firm being the IC disk expert. Oh, that's true, so it even especially nowadays. Yeah, and so it seems like like the average age of IC disks experts is about the same as the average age of the average Fortran computer language programmer. It just seems like you know new people are not coming into the disk and there's just a dearth of knowledge all around. Brian: Right, right. And I myself learned COBOL, which is a choice between Fortran and COBOL, when I was in business school, both equally non-usable. Dave: Is it part of that? Because since the disk came on in 1972, it seems like since 1973, people have been talking about the IC disk going away. So is that maybe part of it? People think, well, why should I learn something if it's going away? Brian: Maybe part of it. People think, well, why should I learn something if it's going away? There's always been a fear that it's either going to go away or that there's a technical correction coming that the disk dividend is not a qualified dividend. But the bottom line is politically, I just don't see that happening. Dave: It stands for too many things that are positive for the US Job creation export sales for too many things that are positive for the US Job creation, export sales, us companies being more competitive in the global market. Brian: So it doesn't really lend itself to be repealed. What can be repealed are some of the tax rates. Some of the tax rates can change and that can change the benefits of the disc. The concept of the disc itself and what it stands for really is very consistent with our country. Dave: Yeah, wow, I can't believe how the time has flown by, brian. Is there anything else that you want to mention about the IC disc or the MRO industry? Brian: No, I can't think of anything specifically other than I'm looking forward to being there and meeting many of the attendees and other exhibitors that are there and spending some time with you and our colleagues in Atlanta. Dave: Yeah, it will be fun. So it's the ICDISC Alliance. If you want to look us up on the website for the conference or stop by 1818BC. We also have a LinkedIn page for the ICDISC Alliance, and so I'd love to meet with any of you who are going to be at the conference. Awesome, well, thank you very much for your time, Brian. This has been really useful. Brian: You're welcome. You're very welcome. Special Guest: Brian Schwam.

Does your nonprofit want to build power and amplify its impact by engaging in robocalling and texting campaigns? Would it surprise you to find out that while this type of advocacy can effectively boost your reach and put you in touch with thousands (even millions) of supporters, it also comes with rules related to opt-out requirements, mandatory disclaimers, prior consent, and more? On this episode, we'll introduce you to our new Robocalling guide and walk through several of the issues your nonprofit needs to think about before you pick up the phone or click send on a robocall or robotext campaign.     Attorneys for this Episode  Monika Graham  Melissa Marichal Zayas  Natalie Ossenfort    Robotext and Robocall Campaigns  Federal Communications Commission (FCC), Federal Trade Commission (FTC), and Federal Election Commission (FEC) each regulate robocalls and robotexts  For example, the Telephone Consumer Protection Act (TCPA), enforced by the FCC, strictly limits when organizations can make robocalls and robotexts. Violations of TCPA can result in stiff fines, so know the rules before you launch your next campaign.  Keep in mind that many states also have their own rules on these communication methods.  Federal Restrictions on Robocalls / Robotexts  What are robocalls and robotexts? Calls or texts made with an autodialer or using an artificial or pre-recorded voice.   Under federal law (the TCPA), a nonprofit organization must obtain an individual's “prior express consent” to: (a) send a call or text to a cell phone using an autodialer, a prerecorded voice, or an artificial voice, or (b) to send more than three prerecorded or artificial voice calls to a landline in a 30-day period.  Express consent requires:  The person gave permission to be contacted at their cell phone number.  The call is within the scope of the consent given.  The person hasn't revoked their consent.  Prior express consent is not the only consideration you need to think about before engaging in robocall or robotext campaigns. Identification, opt-out, and disclaimer requirements are going to be relevant too.  For example, federal law requires that all pre-recorded voice telephone messages to cell phones or landlines must include a specific identification disclaimer. Disclaimer must:  Clearly state at the beginning of the message the official registered name of the organization initiating the call, and  The telephone number of the organization (not the number of the vendor who placed the call, a 900 number, or a number for which charges exceed normal local or long-distance transmission charges).  Disclaimers may also be required if a non 501(c)(3) organization expressly advocates for or against a federal candidate or solicits contributions in relation to a federal election --> triggering federal campaign finance law, which is enforced by the FEC.  This type of disclaimer should not apply to 501(c)(3)s which are prohibited by the Internal Revenue Code from supporting or opposing candidates for public office.  Likewise, the IRS may require a disclaimer if fundraising solicitations are made by non-501(c)(3)s reminding the potential donor that contributions are not tax deductible.    Remember: State Law Matters Too!  Many states restrict certain types of calls, like robocalls. When they do, they often apply to both cell phones and landlines.  In many instances, state laws are similar to the federal rules, but variations between state and federal law do exist, and some states restrict calls that would otherwise be allowed under federal law.  Consult with counsel before launching your campaign because common state law requirements include:  Notification or self-identification requirements  Time restrictions  Geographic limits  Permit requirements  Prohibitions on caller ID blockers  And more!  State law may also require lobbyist or campaign finance registration and reporting in some instances.    FAQ New Robocalling guide contains a handy FAQ, where you can find answers to common questions like:  What are the best ways to collect cell phone numbers for these types of campaigns?  Are landlines treated differently than cell phones?  What happens when a cell phone number is reassigned to someone other than the person who provided consent?    Resources  Robocalling Rules: Before You Pick Up the Phone, Hold That Call. What You Need to Know about Robocalls, Robotexts, and Autodialers