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Court cases, judgements and ongoing coverage of tax topics with a legal perspective
By Colleen Murphy | February 20, 2024
The merger is the firm's third combination of 2024.
3 minute read
By Stuart L. Pachman | February 20, 2024
"Whether one represents the employer or the employee, counsel is wise to consider the legal, tax, and any other consequences that follow when an employee of a corporation or an LLC is to become a co-owner of the entity," writes Stuart Pachman of Brach Eichler.
5 minute read
By Michael A. Mora | February 16, 2024
The jury deliberated for less than 45 minutes, defense counsel said.
4 minute read
By David E. Kahen and Elliot Pisem | February 14, 2024
In 'Estate of Fry v. Commissioner', payments by one S corporation to another under identical ownership were recorded as intercompany loans. Following issuance of a notice of deficiency premised on the shareholder's stock basis in the debtor corporation being insufficient to support the losses claimed by him, the petitioners were ultimately successful in persuading the Tax Court that the transfers should be recharacterized as distributions by one corporation to its shareholder, coupled with contributions by that shareholder to the other corporation.
9 minute read
By Patricia Kane | February 12, 2024
A discussion of disputes and their consequences in tax law. The author writes: "Well-settled in the tax law is the notion that the character of amounts received in the settlement of a claim turns on the underlying nature of the claim."
8 minute read
By Brenda Sapino Jeffreys | February 5, 2024
Greenberg Traurig shareholder Alejandra Garcia Earley, who focuses on project finance and energy tax equity financings, has joined Orrick Herrington & Sutcliffe's energy and infrastructure team as a partner in Chicago.
3 minute read
By Avalon Zoppo | February 2, 2024
Appeals court will consider whether investors have a reasonable expectation of privacy in information they provide to a cryptocurrency exchange platform.
6 minute read
By Jason Feingertz, Katherine Gallagher and Zach Roop | January 29, 2024
States have long grappled with the question of how to properly source the income of an employee who works at home in one state, for an employer in another state. In response to the tax burden placed on its residents and the tax revenue it was losing, in 2023 New Jersey passed its own Convenience of the Employer Rule.
5 minute read
By Joseph T. La Ferlita and Nicholas G. Moneta | January 26, 2024
On Dec. 29, 2023, the Office of the Chief Counsel of the IRS released Chief Counsel Advice Memorandum 202352018 (the CCAM). Although some have commented on the CCAM's impact on trust modifications, a further question is what impact, if any, will the CCAM have on trust decantings in New York?
8 minute read
By Alison Powers Herman and Karen T. Schiele | January 26, 2024
Transferring assets to an intentionally defective grantor trust (IDGT) is a potentially powerful estate planning technique, allowing an individual to pass significant value to his or her intended beneficiaries transfer tax-free.
8 minute read
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