Misty Edwards’ Post

We are thrilled to share that our Firm President, Mike Wilson, has been appointed as the chair-elect designee of the Tax Section of the The Florida Bar Tax Section, effective September 15, 2024. Mr. Wilson will step into the role of chair-elect on July 1, 2025, and will become the Chair on July 1, 2026. His extensive experience and dedication have been invaluable, serving as a long-time director and member of the Executive Council of the Tax Section, including roles in the Federal Tax Division, Educational Division, Section Administration Division, and the Long-Range Planning Committee. For more details, click the link to read the full release! #TaxLaw #FloridaBar #ProfessionalAchievement

We are excited to announce that Robert C. Morris, co-leader of the tax practice at Norton Rose Fulbright, will be speaking at the 2025 STEP Orange County Conference, taking place on February 11-12 at Balboa Bay Resort. Rob is renowned for his expertise in tax controversy matters, representing clients through every stage of IRS interactions—from examinations and mediations to litigation in the U.S. Tax Court. His extensive practice also includes state tax disputes, transfer pricing issues, tax fraud allegations, and criminal tax charges. As a Certified Public Accountant and former “Big Four” accounting firm professional, Rob brings a comprehensive understanding of tax issues. Clients praise his “common-sense approach” and “fantastic, technically excellent” service. His reputation has earned him numerous accolades, including recognition in Chambers and Partners, Legal 500, Texas Super Lawyers, and The Best Lawyers in America. At the 2025 STEP Conference, Rob will provide invaluable insights into navigating complex audits for high-net-worth families, offering both a legal and practical perspective. Key Topics Rob Morris Will Cover: - “Audits from Hell” – IRS examinations of high-net-worth families - What it’s like to face a Global High Wealth Audit from both the IRS and taxpayer perspectives - The impact of the IRS's Strategic Operating Plan and how current and projected funding will shape audits - Special challenges in GHW audits, including corporate jet usage and other high-net-worth audit issues - Partnership audits—past, present, and key considerations at the outset of a BBA audit - Managing statute of limitations, resolving audits, and leveraging alternative dispute resolution methods Rob’s session is a must-attend for those looking to better understand the intricacies of IRS audits and tax law. Don’t miss out—register now to secure your spot! Register here: https://lnkd.in/g-6TW-yb Conference Dates: February 11-12, 2025 Venue: Balboa Bay Resort, Newport Beach, CA #Audit #HighWealthAudit #IRS #GHWaudits #PartnershipAudits #STEPOC #taxcontroversy #ContinuedEducation

🌟 Celebrating Transparency and Innovation in Tax Law 🌟 The ICAEW’s article on Dan Neidle’s remarkable achievement as the top figure in the ROAR x rankings is an inspiring read for anyone interested in tax law, public accountability, and thought leadership. 👏 Dan’s work shines a spotlight on the importance of transparency in the complex world of taxation, highlighting how professionals can use their expertise to drive societal change. His innovative approach, combining deep technical knowledge with accessible public communication, teaches us three key lessons: 1️⃣ Mastery of a technical subject like tax law can be a tool for accountability when shared in the right way. Dan exemplifies how professionals can bridge the gap between complexity and clarity. 2️⃣ Standing up for transparency often requires courage. Dan’s commitment to uncovering the truth demonstrates how integrity remains at the heart of professional excellence. 3️⃣ Taxation might seem like a dry subject, but Dan’s work reminds us that it impacts public trust, governance, and equality. His story is a call for professionals to think about their impact on society. I agree with Dan Neidle because his commitment to transparency in tax law not only holds power to account but also inspires greater public trust in a system that affects us all. As we read about achievements like Dan’s, let’s reflect on how we, too, can lead with purpose and create a positive ripple effect in our industries. 🌍 What do you think about the role of transparency in tax and beyond? #Leadership #TaxLaw #Transparency #ProfessionalExcellence #ICAEW #PurposeDrivenWork https://lnkd.in/egt9vJ5A

This week's Tax Law & Policy Perspectives topic is, "Tax Law & Policy Perspectives: What Is a Grantor Trust?" In this week's post, Monte A. Jackel, UBalt Law’s graduate tax program scholar in residence, provides background relating to grantor trusts and then explains that the law needs congressional authorization to provide clarity relating to what ownership of a grantor trust means. Read more on our blog, and subscribe to never miss a post! https://lnkd.in/gtHaFQzi

Friendly reminder to advisors and clients managing Tax Exempt Organizations; the deadline for Tax Exempt Organizations to file their returns is approaching on May 15, 2024. The filing thresholds for the Form 990-series is as follows: -gross receipts equal or less than $50k can file Form 990-N; -gross receipts less than $200k and total assets less then $500k can file Form 990-EZ; -gross receipts equal to or greater than $200k and total assets equal to or grater than $500k can file Form 990 -Private foundations must file Form 990-PF Unfortunately, many smaller organizations fail to file their Form 990. Organizations which fail to file their Form 990 for three (3) consecutive years will automatically lose its tax exempt status. Typically, we see the same recurring issues with these types of companies: (1) lack internal structure which clearly delegates filings responsibilities among officers; (2) high officer turnover resulting in lack of institutional knowledge about filing requirements; and (3) lack of a relationship with competent counsel. For Massachusetts tax exempt organizations; remember to annually file: (1) Form 990; (2) Form PC with the Attorney General's Office; and (3) annual reports with the Secretary of State's office (if the underlying entity is a corporation). If you advise a tax exempt organization or are an officer of a tax exempt organization and need help either bringing your entity back into compliance or need advice to create better internal structures to avoid these issues; then please feel free to reach out to myself or one of the attorneys in our corporate department. #taxexemptorganization #501(c) #corporate https://lnkd.in/eEhQRCpN

This is concerning and dangerous on so many levels

Congratulations, Lou! Louis Vlahos was voted number one in JD Supra’s 2024 Readers’ Choice Awards on the topic of tax. The Readers’ Choice Awards recognize top authors and firms who were read by C-suite executives, in-house counsel, media, and other professionals across the JD Supra platform during 2023. To read more, please visit https://lnkd.in/eVQs6WCA #TaxSlaw #TaxLaw #taxlawyer

Have a look back at our interview with Clair Dart, Corporate Tax Partner at Alliotts LLP. Clair explains what has inspired her to become a senior figure in her sector and shares views on why people are leaving the tax industry. Learn from a leading tax professional and what it takes to succeed in your career. Clair was talking to Robert Hunter, Tim Keech and Rory Bysouth at AJ Chambers. 👉 https://lnkd.in/eRa45ScA #tax #accountancy #taxindustry

The Solicitors Disciplinary Tribunal has upheld a claim against Osborne Clarke partner Ashley Hurst regarding his conduct in Strategic Lawsuits Against Public Participation (SLAPP) correspondence. Hurst had been corresponding with Dan Neidle, a former Clifford Chance tax partner, about Nadhim Zahawi’s tax affairs. The Solicitors Regulation Authority alleged that the respondent sent written correspondence that improperly attempted to restrict Neidle’s right to publish and/or discuss specific matters regarding the Former Chancellor of the Exchequer's tax affairs and legal repercussions that may follow if he did. The case, brought by the SRA, rested heavily on an e-mail and letter that Hurst sent to Neidle on 16 July 2022 and 19 July 2022, respectively. The SDT found that in the email Hurst acted improperly and the case against him was upheld. The claim regarding the letter was dismissed. This marks the first time a lawyer has faced tribunal over a reported SLAPP, with the legal industry closely monitoring the SDT's outcome for future implications. A spokesperson for Osborne Clarke said: "We are extremely surprised and disappointed with this outcome in light of the legal position and evidence heard at the Tribunal. We will await the detailed reasons of the Tribunal before commenting further." Full story from Molly Smith: https://lnkd.in/g2z6yvjD

The #Tax fallout of Loper Bright: Varian Medical Systems. The Tax Court's August 24, 2024 decision in Varian Medical Systems Inc. v. Commissioner addressed how it will evaluate Treasury regulations following the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo. As a reminder, Loper Bright overturned the #Chevron doctrine, which mandated judicial deference to agency regulations when interpreting ambiguous statutory language. In Varian, the Tax Court found that the statute was clear, making the contrary regulation invalid under Chevron. However, what was noteworthy was Judge Emin Toro's discussion of Loper Bright, indicating the court's future approach to Treasury Regulations. The taxpayer in Varian argued that the statute’s text was unambiguous. The Commissioner initially contended the statute was ambiguous and the regulation was therefore permissible under Chevron. Following Loper Bright, Judge Toro requested input on its impact and agreed with the taxpayer, declaring the regulation invalid due to the statute's clear meaning. Judge Toro emphasized that, under Loper Bright, courts must determine a statute’s “single, best meaning” without deferring to agency interpretations if the statute’s text is clear. The resulting doctrine has the court considering Treasury’s views but independently judging whether Treasury has stayed within its statutory authority. The thoroughness and consistency of Treasury’s views influences their weight. The court emphasized that policy concerns cannot override clear statutory text, and improving policy outcomes is Congress’s role, not the courts’. The entire Tax Court concurred with Judge Toro’s opinion, signaling that it will evaluate future challenges to Treasury regulations under the standards established in Varian. The loss of #Chevron deference has upended many legal fields, and future cases will be needed to determine new standards for regulatory interpretation. How has the #LoperBright decision impacted your practice? #tax #taxcourt #law #scotus #treasury #government