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Connecticut State & Local Tax Alert
IRS Proposes New Regulations on Nondiscrimination for Tax-Exempt Schools
By Julie C. Fay, Melissa Mack, Deanna McWeeney, Tom Owen
In September 2025, the Internal Revenue Service (IRS), jointly with the Department of the Treasury, issued its Priority Guidance Plan (“Plan”) for the 2025-2026 fiscal year. In this Plan, the IRS signaled…
Nonprofit Law Prof Blog
Aprill, Is OpenAI Foundation a Private Foundation? Should It Be?
Ellen P. Aprill (Loyola L.A.) has posted Is OpenAI Foundation a Private Foundation? Should It Be? Here is the abstract: The saga leading to the recapitalization of OpenAI into a…
Alcohol & Food Law
What Does a TTB Permit Look Like?
If you’re starting an alcohol business, one of the first questions you may have after applying for a federal permit is surprisingly simple: What does a TTB permit actually look…
Tax Break Down
“Stacking” the Deck: Treasury Takes Aim at QSBS Trust Planning
By Jacquelyn Dunne[1] and Rachel Partain Qualified Small Business Stock (“QSBS”) is a valuable tax incentive available to founders, investors, and employees of startups. Section 1202 permits shareholders to exclude…
TaxSlaw
Taxing NYC’s “Wealthy” By Reducing The Credit For Unincorporated Business Tax
By Louis Vlahos
Taxes Galore There are so many things that New York City has in abundance. Some are good while others are less desirable. It often depends upon whom you ask. One…
ERISA Litigation & Compliance
“Double Dip” Health Plans Marketed to Employers: Too Good to Be True
By Shira McKinlay, Dominic DeMatties, Kim Wilcoxon, Katherine B. Kohn
Every few years, promoters resurface with new “double dip” health plan products promising employees more take‑home pay and employers big employment‑tax savings. The pitch is familiar: employees pay large pre‑tax…
Tax Talks
Fifth Circuit Withdraws Sirius Solutions Opinion and Adopts New “Significant Role” Standard for the Limited Partner Exception
By Richard M. Corn, Laura Gavioli, Abraham Gutwein, Martin T. Hamilton, Christine Harlow, Arnold P. May, David S. Miller, Jeremy Naylor, Amanda H. Nussbaum, Stephen Severo, Jacqueline Watson
On August 12, 2026, in K Alain, L.L.L.P. v. Commissioner,[1] the U.S. Court of Appeals for the Fifth Circuit withdrew its taxpayer-friendly January 16, 2026 opinion in Sirius Solutions, L.L.L.P.…
Roberts Disability Law Blog
Northern District of California District Court Denies Rule 59(e) Relief and Cuts ERISA Fee Award for Non-Specialist Counsel
In Woo v. Kaiser Foundation Health Plan, Inc., No. 23-cv-05063-RFL, 2026 WL 2445072 (N.D. Cal. Aug. 19, 2026), United States District Judge Rita F. Lin denied Plaintiff’s motion to alter…
Wills, Trusts & Estates Prof Blog
Initial Consequences of the GST Final Regulations for Taxpayers
By Teddy Groce
The Internal Revenue Service (IRS) issued final regulations for generation-skipping transfer (GST) tax exemption allocation relief on May 6, 2024. To summarize, the final regulations changed the process for taxpayers…
TaxSlaw
Identifying “Limited Partners” for the Exclusion from Self-Employment Tax – The Fifth Circuit Changes its Mind…Sort of
By Louis Vlahos
An About-Face? Earlier this year, the federal Court of Appeals for the Fifth Circuit[i] ruled that the U.S. Tax Court had misinterpreted the Code’s self-employment tax rules as they apply…