By Dan Roe | March 12, 2024
Steven Lorch is the fifth energy partner to join the firm in the past year.
New York Law Journal | Analysis
By Conrad Teitell | February 23, 2024
Each year, the IRS adjusts charitable gift rules, tax tables, personal exemptions, standard deductions and other tax provisions. This article highlights the key charitable figures for 2024.
New York Law Journal | Analysis
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.
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."
New York Law Journal | Analysis
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?
New York Law Journal | Analysis
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.
New York Law Journal | Analysis
By Susan Rothwell | January 26, 2024
The purpose of this article is to alert practitioners to how easily a foreigner's New York estate can be compelled to bring a proceeding in a New York Surrogate's Court and owe federal (and sometimes state) estate taxes, all of which add significant expense and delays before beneficiaries can receive the New York property.
New York Law Journal | Analysis
By Jeremy H. Temkin | January 17, 2024
Over the past year, federal courts have issued decisions clarifying the extent to which §6103 shields tax returns and return information from disclosure in civil litigation, the extent to which the IRS is permitted to disclose confidential information during and in connection with investigations, and the application of a safe harbor shielding the government from liability for unauthorized disclosures.
By Philip Wagman, Chair, Tax Section | January 16, 2024
Philip Wagman, chair of the Tax Section, writes: The Tax Section provides members with opportunities to research and learn more about these tax issues and a host of other current developments in the tax law.
By Ezra Dyckman and Charles S. Nelson | December 26, 2023
Ezra Dyckman and Charles Nelson discuss the Inflation Reduction Act, which has expanded the scope of green energy tax credits, and also proposed regulations by the Treasury Department that have the potential to allow even taxpayers with no income tax liability to more easily monetize some of these tax credits.
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