News of the comment letter appeared in tax industry publications such as Tax Notes.

Andersen Managing Director Joe Calianno's article IRS Provides Favorable Result to the Mid-Year Distribution/Section 961 Basis Issue appears in The Journal of International Taxation (WG&L).

Andersen Managing Director Mary Duffy's insights were featured in Bloomberg's latest news piece, Treasury Issues Proposed Semiconductor Chips Tax Credit Rules, which outlined the latest proposed regulations from the IRS on the research and manufacturing of semiconductor chips.

Philanthropy is often a rewarding way for wealthy individuals and entrepreneurial families to make a difference in the world and leave a legacy. Many individuals have established private foundations under Sec. 501(c)(3) to conduct these activities. However, legislative changes in recent years have made Sec. 501(c)(4) social welfare organizations (501(c)(4) organizations) a potentially more attractive option to supplement some individuals’ existing philanthropic efforts.

Throughout 2022, as the seemingly endless rush of headlines indicated, the Federal Reserve raised the Federal Funds Rate by approximately 4.25%, from a .25% rate in March 2022 to a 4.5% rate at the end of the year, the fastest pace of rate increases in U.S. history. In the low-interest rate environment of the last 15 or so years, low-rate interest driven transactions employed by high net worth individuals were extremely effective in planning, which includes charitable planning. While such planning should and will continue, given how significantly interest rates in the U.S. have recently risen and could continue to rise in 2023, charitably inclined clients should consider the effect these rate increases will have on such charitable planning techniques. This article explores the impact of rising interest rates on two common charitable trust structures, Charitable Remainder Trusts (CRTs) and Charitable Lead Trusts (CLTs).

With the widespread adoption and use of cryptocurrencies around the world, companies and individuals are increasingly encountering situations that require a valuation of their cryptocurrency assets. As a fundamental matter, IRS recently issued guidance requiring that cryptocurrencies be treated and appraised as property, rather than securities. In Chief Counsel Advice Memorandum ILM 202302012 (released January 10, 2023), IRS advised that a taxpayer who makes a charitable donation of more than $5,000 of cryptocurrency must submit a qualified appraisal of its fair market value (FMV) to qualify for a charitable deduction under Sec. 170(a) and cannot satisfy this requirement by relying on the cryptocurrency's value as listed on an exchange.