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December 22, 2020 | New York Law Journal

Treasury Issues Final Regulations Under Section 163(j)

On Nov. 26, 2018, the Treasury Department issued proposed regulations under Section 163(j), and on July 28, 2020, these regulations were finalized. The final regulations largely adopt the proposed regulations, but with some important modifications that are generally favorable to taxpayers.
6 minute read
December 16, 2020 | New York Law Journal

Tax Treatment of Damages for Accountant Malpractice: 'McKenny v. United States'

A taxpayer suffers a loss by reason of errors made by a tax advisor, and the tax advisor makes a payment to compensate the taxpayer for the loss. May the payment be excluded from the taxpayer's income subject to tax? In this edition of their Taxation column, David E. Kahen and Elliot Pisem discuss a recent decision in which the Eleventh Circuit court concluded that the taxpayers before it could not exclude the payment at issue from income.
8 minute read
October 23, 2020 | Law.com

Litigators of the Week: The Boies Schiller Duo Who Fought to Make Ghislaine Maxwell's Depo Public

"We have lived this case for so long and it feels liberating to have some of the veil lifted off of these materials," said Sigrid McCawley of Boies Schiller Flexner.
7 minute read
October 23, 2020 | Litigation Daily

Litigators of the Week: The Boies Schiller Duo Who Fought to Make Ghislaine Maxwell's Depo Public

"We have lived this case for so long and it feels liberating to have some of the veil lifted off of these materials," said Sigrid McCawley of Boies Schiller Flexner.
7 minute read
October 20, 2020 | New York Law Journal

More Liabilities Please: The Allocation of a Partnership's Liabilities

In October, 2019, the Treasury Department finalized a set of regulations that will have an important impact on how liabilities are allocated when a partner guarantees partnership debt. In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the importance of the allocation of a partnership's liabilities.
5 minute read
October 14, 2020 | New York Law Journal

'Deckard': Failure to Establish Stock Ownership Defeats S Corp Shareholder Treatment

In their Taxation column, David E. Kahen and Elliot Pisem examine how an irregularity in corporate form may invalidate an election and give rise to adverse consequences that become apparent only in the context of a tax audit years after the election was attempted.
8 minute read
October 05, 2020 | Texas Lawyer

Newsmakers: Week of Oct. 5, 2020

Lawyer and state Rep. Travis Clardy has joined Holland & Knight as of counsel in the firm's Austin office.
6 minute read
September 10, 2020 | New York Law Journal

'Mars' Highlights Limits of City Conformity to Federal Tax Principles

In their Tax Appeals Tribunal column, Joseph Lipari and Aaron S. Gaynor discuss a recent administrative law judge determination that highlights the question of whether and how federal tax principles apply to New York state and city taxes in situations other than an express decoupling.
7 minute read
August 25, 2020 | New York Law Journal

Not Getting Carried Away: Proposed Regulations on Carried Interest

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the proposed Treasury regulations under Section 1061 which clarify provisions of the carried interest rules.
5 minute read
August 19, 2020 | New York Law Journal

Vesting and Rescission: Estate of 'Kechijian v. Commissioner'

In their Taxation column, David E. Kahen and Elliot Pisem discuss Estate of Kechijian v. Commissioner, the third opinion addressing tax consequences of a 1998 acquisition of stock by Larry Austin and Arthur Kechijian.
10 minute read

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