Tax

In almost two decades of litigating cases tied to the Section 41 R&D credit, ZMFF&J has worked with taxpayers big and small to defend credit claims. Every once in a while, though, a case comes across our desks that carries the gravitas of an entire industry, and not just one taxpayer. Last month’s validation of…

The One Big Beautiful Bill Act (the “OBBBA”), signed into law on July 4, 2025, expanded the tax on excess tax-exempt organization executive compensation imposed under Section 4960 of the Internal Revenue Code, as amended (the “IRC”). The change affects any applicable tax-exempt organization (“ATEO”) that pays remuneration exceeding $1 million as well as certain…

Introduction- In January 2025, the Internal Revenue Service (“IRS”) released final regulations related to cloud transactions and digital content. These new rules, effective for tax years beginning January 14, 2025, clarify how these types of transactions are classified and, for the first time, provide a structured framework for sourcing income from cloud-based activities. -What is…

If a foreign taxpayer conducts work in the U.S., do they owe taxes? It’s a question that, for many foreign taxpayers, has created headaches and uncertainty. Foreign individuals who engage in a United States trade or business (“USTB”) very likely owe tax on what is considered to be “Effectively Connected Income” (“ECI”). In general, when…

Is your business making payments to foreign persons, including non-resident alien individuals or foreign entities? If so, depending on the character and source of the payment, a U.S. payor may have a withholding obligation and related reporting requirements. This Q&A is intended to summarize on a high-level, the guidelines of how certain payments made to…