Podcasts about irs chief counsel

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.

On this episode of tax break, host Rob Kovacev interviews former IRS Chief Counsel and newest addition to the Miller & Chevalier tax practice, Mike Desmond. They discuss Mike's tenure as Chief Counsel, the challenges facing the IRS under the new administration, and the changing legal landscape for Treasury regulations. ********* Thank you to Mike Desmond for joining us: https://www.millerchevalier.com/professional/michael-j-desmond  Questions? Contact us at podcasts@milchev.com. tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts. tax break is a podcast about tax law, brought to you by Miller & Chevalier. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

In S06E09, Bela Unell and Professor Roberta Mann discuss her early career at IRS Chief Counsel, how her experience on Capitol Hill shaped how she views law today, and her approach to teaching tax.

A monthly review of US international tax-related developments. In this edition: OECD releases final guidance on BEPS Pillar One Amount B on baseline distribution – Finalization of proposed FX regulations expected by year end, two sets of proposed Section 367 regs in first half of 2024 – US Senate approves IRS Chief Counsel nomination – IRS sending more letters regarding transfer pricing compliance – OECD releases 2024 update on peer reviews under BEPS Action 5 on harmful tax practices.

A review of the week's major US international tax-related news. In this edition: US House of Representatives passes tax package; Senate action unclear – IRS expects to finalize two sets of Section 367 proposed regulations in first half of 2024 – Senate Finance Committee again approves IRS Chief Counsel nomination – OECD releases first statistics on ICAP.

A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

A monthly review of US international tax-related developments. In this edition: US Senate Finance Committee approves US-Taiwan tax bill – House Republicans want countries to delay BEPS Pillar Two, adopt GILTI-like regime – Senate Finance Committee considers IRS Chief Counsel pick – IRS publishes additional interim guidance clarifying CAMT – IRS announces intent to issue proposed regulations for Section 174, would affect cost sharing arrangements – US Government considering extension of temporary FTC relief, guidance on taxes paid under BEPS Pillar Two – IRS official offers international regulatory update – IRS CAP program accepting new applications – IRS announces major new compliance initiative targeting large partnerships.

A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada's DST proposal.

A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

Our international expat team had a discussion with Mishkin Santa, JD, LLM, TEP from The Wolf Group about recent and relevant court cases that directly impact expats when it comes to tax filing. The Wolf Group thrives as an international tax accountant firm. Mishkin is a Principal of The Wolf Group and oversees the firm's international tax services in the areas of Offshore Voluntary Disclosure, US Exit Tax, foreign grantor and non-grantor trusts, nonresident alien taxation, international organization employee taxation, pre-immigration tax planning, and cryptocurrency. He assists individuals and businesses with highly specialized and complex tax issues related to offshore corporations, family businesses, trusts, and retirement plans. As a former Attorney with the IRS Chief Counsel, Mishkin is well-positioned to guide clients on a range of reporting and disclosure issues. In addition, he speaks regularly at professional events sponsored by attorney and CPA groups in the US and abroad. --- Send in a voice message: https://podcasters.spotify.com/pod/show/walkner-condon-expats/message

Welcome to THE Sports Law Podcast! We keep you informed on everything at the intersection of sports and the law. The world of Name, Image, and Likeness keeps moving forward as Tarun (@tksharmalaw), Mike (⁠⁠⁠⁠⁠@Mike_sonof_Law⁠⁠⁠⁠⁠), and Holly (⁠@SlamDunkSummers⁠) break down the latest updates in NIL. Amanda Christovich (@achristovichh) from Front Office Sports joins us! The NCAA Student Athlete Advisory Committee ("SAAC") sent letters to Congress advocating for federal NIL. (2:19) Amanda joins to discuss her latest article on Front Office Sports about the letters sent from all three divisions. The D1 SAAC letter was the only one not signed by all members of SAAC, being signed only by the D1 Chair. Amanda's discusses that these letters were clearly written or edited by the NCAA before being sent and published because all of the points were favorable to the NCAA, like no employee status and an antitrust exemption. You can read Amanda's article here. The IRS Chief Counsel sent a memo regarding NIL Collectives and their tax-exempt status. (24:40) This memo, which is not precedent or binding, is a warning to all collectives who provide tax-deductible donations to student athletes, as they are "not incidental both qualitatively and quantitatively to any exempt purpose." Many of these collectives have already been granted 501(c)(3) tax exemption status, but this memo states that the IRS will be monitoring their activities to make sure that there are no direct benefits being made for private interests. This memo is a blanket warning to all NIL Collectives seeking tax exempt status or those who are currently tax exempt. Baby Gronk has been making waves on social media. (38:33) Madden "Baby Gronk" is currently a 4th grader and has been touring the country to many schools as a prospective football athlete. The issue many are taking with this is that he is being controlled by his father and many are saying Baby Gronk's father is "clout chasing" his son for NIL. *** Have a topic you want to write about? ANYONE and EVERYONE can publish for ⁠⁠⁠⁠⁠⁠⁠⁠ConductDetrimental.com⁠⁠⁠⁠⁠⁠⁠⁠. Let us know if you want to join the team. Hosts: Dan Wallach (⁠⁠⁠⁠⁠⁠⁠⁠@WallachLegal⁠⁠⁠⁠⁠⁠⁠⁠) | Dan Lust (⁠⁠⁠⁠⁠⁠⁠⁠@SportsLawLust⁠⁠⁠⁠⁠⁠⁠⁠) Producers: Mike Lawson (⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠@Mike_sonof_Law⁠⁠⁠⁠⁠⁠) ⁠⁠⁠⁠⁠⁠⁠⁠Twitter⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Instagram⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠TikTok⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠ YouTube⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Website⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Email --- Support this podcast: https://podcasters.spotify.com/pod/show/condetrimental/support

Welcome to THE Sports Law Podcast! We keep you informed on everything at the intersection of sports and the law. The world of Name, Image, and Likeness keeps moving forward as Tarun (@tksharmalaw), Mike (⁠⁠⁠⁠⁠@Mike_sonof_Law⁠⁠⁠⁠⁠), and Holly (⁠@SlamDunkSummers⁠) break down the latest updates in NIL. Amanda Christovich (@achristovichh) from Front Office Sports joins us! The NCAA Student Athlete Advisory Committee ("SAAC") sent letters to Congress advocating for federal NIL. (2:19) Amanda joins to discuss her latest article on Front Office Sports about the letters sent from all three divisions. The D1 SAAC letter was the only one not signed by all members of SAAC, being signed only by the D1 Chair. Amanda's discusses that these letters were clearly written or edited by the NCAA before being sent and published because all of the points were favorable to the NCAA, like no employee status and an antitrust exemption. You can read Amanda's article here. The IRS Chief Counsel sent a memo regarding NIL Collectives and their tax-exempt status. (24:40) This memo, which is not precedent or binding, is a warning to all collectives who provide tax-deductible donations to student athletes, as they are "not incidental both qualitatively and quantitatively to any exempt purpose." Many of these collectives have already been granted 501(c)(3) tax exemption status, but this memo states that the IRS will be monitoring their activities to make sure that there are no direct benefits being made for private interests. This memo is a blanket warning to all NIL Collectives seeking tax exempt status or those who are currently tax exempt. Baby Gronk has been making waves on social media. (38:33) Madden "Baby Gronk" is currently a 4th grader and has been touring the country to many schools as a prospective football athlete. The issue many are taking with this is that he is being controlled by his father and many are saying Baby Gronk's father is "clout chasing" his son for NIL. *** Have a topic you want to write about? ANYONE and EVERYONE can publish for ⁠⁠⁠⁠⁠⁠⁠⁠ConductDetrimental.com⁠⁠⁠⁠⁠⁠⁠⁠. Let us know if you want to join the team. Hosts: Dan Wallach (⁠⁠⁠⁠⁠⁠⁠⁠@WallachLegal⁠⁠⁠⁠⁠⁠⁠⁠) | Dan Lust (⁠⁠⁠⁠⁠⁠⁠⁠@SportsLawLust⁠⁠⁠⁠⁠⁠⁠⁠) Producers: Mike Lawson (⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠⁠@Mike_sonof_Law⁠⁠⁠⁠⁠⁠) ⁠⁠⁠⁠⁠⁠⁠⁠Twitter⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Instagram⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠TikTok⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠ YouTube⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Website⁠⁠⁠⁠⁠⁠⁠⁠ | ⁠⁠⁠⁠⁠⁠⁠⁠Email --- Support this podcast: https://podcasters.spotify.com/pod/show/condetrimental/support

A review of the week's major US international tax-related news. In this edition: Republican House Ways and Means Committee members expected to release business tax package – IRS provides CAMT estimated tax penalty relief – IRS planning more guidance for US inbound and outbound IP transfers – Rollinson nominated to be next IRS Chief Counsel.  

A monthly review of US international tax-related developments. In this edition: US tax treaty negotiations with Israel, Switzerland set to start, pending treaties require TCJA updates – IRS PTEP regs coming in Q1 2023, Section 367(d) guidance possible this year – Proposed IRS regulations coming on application of noncompulsory payment regs to certain amended Puerto Rico tax decrees – IRS Chief Counsel memo clarifies process for determining assessment statute expiration date in multi-year Section 332 liquidation – Sixth Circuit rules in favor of Eaton Corporation in APA cancellation – OECD holds public consultation meeting on Progress Report on Amount A of BEPS Pillar One – OECD issues bilateral APA manual – OECD's Pascal Saint Amans announces plans to retire.

In S04E05, William Schmidt and Michael Desmond discuss his time as IRS Chief Counsel, the benefits of public service, and the opportunities available at ABA Tax Section meetings.

This week, Andrew Belter and William Schmidt look at some U.S. Tax Court topics. First, the case Boechler v. Commissioner is before the U.S. Supreme Court where they have heard oral arguments.  In brief, an individual was a day late and missed the statutory deadline for a Collection Due Process hearing.  The Tax Court ruled that there was a strict jurisdictional deadline.  At issue before the Supreme Court is whether that deadline is jurisdictional or if equitable tolling can provide any relief. Second, there was a discussion on the ABA Section of Taxation's Pro Bono and Tax Clinics Committee listserv regarding Answers from IRS Chief Counsel in Tax Court.  For years 1983-2007, the Tax Court did not require answers in S cases.  We discuss the pros and cons of Answers, plus suggestions for what could replace them. Note:  the phrase we couldn't remember was financial disability.  William covered that topic way back in episode 55.  To learn more, you can also look at Internal Revenue Code section 6511(h), Rev. Proc. 99-21 or IRS Publication 556, page 15.  

Just what does IRS Chief Counsel do? Well, they represent the IRS as their client. What does that mean? In this episode, I unpack different job items that IRS Chief Counsel does beyond go to U.S. Tax Court.   For example, Chief Counsel advise on different legal matters for other divisions of the IRS. What else do they do? Tune in to learn more.   For finding out all kinds of information on the Office of IRS Chief Counsel, head here: https://www.jobs.irs.gov/resources/job-descriptions/irs-office-chief-counsel

In S03E06, James Creech and Krista Wood discuss learning tax law, working with the IRS Chief Counsel's Office, and working and learning in the time of Covid.

Join Caroline Ciraolo of Kostelanetz & Fink, LLP as she discusses what is happening at IRS Office of Chief Counsel with our IRS Chief Counsel, Michael Desmond, from the New England IRS Representation Conference. Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/

Join Caroline Ciraolo of Kostelanetz & Fink, LLP as she discusses what is happening at IRS Office of Chief Counsel with our IRS Chief Counsel, Michael Desmond, from the New England IRS Representation Conference.     Want to listen and watch the ENTIRE 2020 IRS Representation Conference? Download ALL the Recordings and Handouts! Purchase now at a special rate! – https://irsrepconference.com/2020-irs-representation-conference-recordings-and-handouts-purchase/

Tax Notes legal reporter Nathan J. Richman talks with IRS Chief Counsel Michael J. Desmond about pivoting to virtual settlement days amid the coronavirus pandemic. For additional coverage, read these articles in Tax Notes:Lessons From Virtual Settlement Days Could Help Future EventsWork-From-Home Technology Comes With New Privilege ConcernsVirtual Settlement Days Will Continue, IRS SaysIRS Collection Officials Seeing Settlement Day BenefitsIRS Considering Long-Term Benefits of Settlement Conference DaysIRS Settlement Conference Day Guide Implies Timing Flexibility***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Guest: Ryan Firth, CPA & Shehan Chandrasekera, CPA Virtual currency experts Ryan Firth, CPA and Shehan Chandrasekera, CPA will discuss what you need to know about the recent IRS revenue ruling on virtual currencies to help you advise your clients: What is virtual currency and cryptocurrency? What are hard forks and airdrops? What are the key takeaways from the IRS Q&A? What are the practical challenges you need to be aware of? How can you help your clients who transact in cryptocurrency? Access the related resources from this podcast: IRS Rev. Rul. 2019-24 Article: “IRS Revenue Ruling 2019-24: Hard Forks, Airdrops and Other Topics Related to the Taxation of Virtual Currency” by Ryan Firth How the IRS is Approaching Cryptocurrency Compliance: Updates from the IRS Chief Counsel New IRS Cryptocurrency Tax Guidance IRS and FinCEN clarify cryptocurrency reporting rules: Like-Kind Exchanges, Specific ID, FBAR, and Airdrops Podcast: Planning & tax considerations when transacting in virtual currency Webcast: IRS Guidance on Taxation of Virtual Currency Demonstrate your competency in personal financial planning with the CPA/PFS credential or the PFP certificate program The episode is brought to you by the AICPA’s Personal Financial Planning Section, the premier provider of information, tools, advocacy and guidance for professionals who specialize in providing tax, estate, retirement, risk management and investment planning advice and by the CPA/PFS Credential program which allows CPAs to demonstrate competence and confidence in providing these services to their clients. Visit us online at www.aicpa.org/pfp to join our community and gain access to valuable member-only benefits. Don’t miss an episode – subscribe to our podcast series on iTunes or Pod-o-Matic or Spotify!. Just search for “AICPA Personal Financial Planning” on any Apple, Android or Windows device.

In S02E01, James Creech and Keith Fogg discuss working in the IRS Chief Counsel office, transitioning to teaching, clinical law, and blogging. (Part 1 of 2.)

Next week is the ABA Tax Section 2019 May Meeting in Washington, D.C. (May 9-11).  I talk about some highlights and panels I might attend.  IRS Commissioner Charles Rettig will be speaking twice, basically at the beginning and end of the conference (Tax Bridge to Practice and the plenary luncheon).  I also detail the Collection Due Process panel I will be on with Carolyn Lee (Morgan, Lewis and Brockius of San Francisco) moderating and panelists Tax Court Judge David Gustafson, Keith Fogg of Harvard Law School, Mitch Hyman of IRS Chief Counsel, Professor Erin Stearns from the University of Denver LITC, and me (William Schmidt, Kansas Legal Services LITC).  We hope it is an innovative panel, bringing discussion of possible solutions to help taxpayers through the process.  It would be wonderful if the panel leads to further discussion that brings systemic change in CDP for the better. The next episode will be posted following the conference.

In CCA 201651013, the IRS Chief Counsel concludes that a trust is not entitled to claim a charitable income tax deduction despite a modification of the trust to permit charitable distributions. Bob Keebler reports. The full text of CCA 201651013 can be found at https://www.irs.gov/pub/irs-wd/201651013.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

In CCA 201651013, the IRS Chief Counsel concludes that a trust is not entitled to claim a charitable income tax deduction despite a modification of the trust to permit charitable distributions. Bob Keebler reports. The full text of CCA 201651013 can be found at https://www.irs.gov/pub/irs-wd/201651013.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Obama Administration’s FY 2016 Budget proposes major overhaul of US international tax system – IRS finalizes regulations under Section 909 foreign tax credit splitting events – IRS Chief Counsel memo addresses application of tax rate disparity test for foreign sales branches – IRS concludes US shareholder must increase E&P in year of Section 951(a)(1) inclusion – IRS releases competent authority agreement with Kazakhstan on treaty benefits for fiscally transparent entities – OECD addresses BEPS Actions 5, 13, and 15 – OECD holds public consultation on BEPS Action 4 on interest deductions and other financial payments.