New York Law Journal | Analysis
By David E. Kahen and Elliot Pisem | October 18, 2023
'Hyatt Hotels v. Commissioner' underscores that even an approach to accounting for income and expenses that has been applied consistently by a taxpayer over many years is not necessarily a "method of accounting" subject to the government's broad power to impose adjustments under Section 481(a).
New York Law Journal | Analysis
By Michael B. Kaufman and Joseph A. Giglio | October 12, 2023
Section 1202 of the Internal Revenue Code provides substantial benefits to non-corporate shareholders of certain C corporations. Clients should be aware of the benefits and risks associated with forming or acquiring different types of entities.
By Sofya Uvaydov and Tim Capowski | October 12, 2023
In personal injury claims where the two sides have disparate valuations based in part on substantial interest accrual, there exists an underused tool for bridging the difference and reaching an accord.
New York Law Journal | Analysis
By Sidney Kess | September 27, 2023
Most tax-related informational-type returns are filed with the IRS in coordination with income tax filing deadlines. However, there is at least one major deadline involving foreign assets that now requires filing with the Treasury. Another major reporting development involving the IRS and third-parties includes new filing rules.
New York Law Journal | Analysis
By Jeffrey A. Galant | September 21, 2023
Selling taxpayers often ignore or fail to appreciate the full picture of their sale transaction. This article examines two recent Tax Court cases in which taxpayers incorrectly accounted for the consideration received as sellers of property.
New York Law Journal | Analysis
By Joseph Lipari and Aaron Gaynor | September 20, 2023
The 'Jefferies Group and Subsidiaries' case involved refund claims of over $10 million. While the Tax Division, among other challenges, objected to numerous positions taken on the corporate returns, the New York State Division of Tax Appeals rejected almost all claims made by the Tax Division.
New York Law Journal | Analysis
By Jeremy H. Temkin | September 13, 2023
This column examines an emerging split over the treatment of 26 U.S.C. §6213(a), which provides taxpayers seeking relief from deficiencies found by the IRS with 90 days to file their Tax Court petitions.
New York Law Journal | Analysis
By Juliya L. Ismailov | September 10, 2023
There has been an inflection point in the economy as a result of work life returning to a new post-pandemic normal. These changes are, in turn, impacting employees' choice of domicile for trust and estate planning purposes, among other things. In this article, Juliya L. Ismailov explores the far-flung tax consequences of post-pandemic recovery.
New York Law Journal | Analysis
By Sharon L. Klein | September 10, 2023
The first year of the 2023-2024 legislative session began Jan. 4, 2023 and ended June 8, 2023. In this article, Sharon L. Klein highlights some of the most significant developments.
New York Law Journal | Analysis
By Barry Black and Christopher Byrnes | August 30, 2023
Counseling a religious entity is different from advising other not-for-profit corporations due to the special rules applicable to, and the constitutional protections afforded to, religious organizations in the United States.
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