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April 19, 2023 | New York Law Journal

Taxing the Donor Upon the Sale of Donated Shares: 'Estate of Hoensheid'

In their Taxation column, Elliot Pisem and David E. Kahen discuss "Estate of Hoensheid v. Commissioner," where it was found that the valuation of shares did not meet the requirements of a qualified appraisal under section 170. The authors write: "The discussion in the opinion underscores the need to engage a qualified appraiser and for such further steps as are necessary to be taken to assure that the appraiser's report complies with the requirements of a qualified appraisal."
10 minute read
March 02, 2023 | New Jersey Law Journal

New Partners Yearbook 2023

Congratulations to these new partners, made and hired laterally over the past year.
52 minute read
February 28, 2023 | New York Law Journal

Pending NY Regulations Portend Increased Scrutiny of P.L. 86-272 Protections for Foreign State Corporations

While most of the updated regulations correspond to New York's own corporate tax reforms, others take the opportunity to address recent court decisions and similar impetuses for change.
9 minute read
February 21, 2023 | New York Law Journal

IRS Issues Guidance on Developers' Common Improvements

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the recently issued Revenue Procedure 2023-9, in which the IRS provides an optional safe harbor method for developers to account for certain common improvement costs of real estate projects.
5 minute read
February 15, 2023 | New York Law Journal

Deductions for Amounts Paid By S Corporation Shareholders Fall between the Cracks

In their Taxation column, David Kahen and Elliot Pisem discuss two recent Tax Court memorandum decisions which underscore the importance of taking applicable tax rules into account when decisions are being made as to how to incur and report expenses, with a view to minimizing the potential for issues to arise on audit.
9 minute read
Law Journal Press | Digital Book New Jersey Tax Handbook 2024 Authors: Robert F. Connolly, MST, Susan K. Dromsky-Reed, Jeffrey D. Gordon, Tiffany Wagner Donio, Frances B. Stella, Alysse Mcloughlin, Kathleen Quinn View this Book

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January 24, 2023 | Supreme Court Brief

The Supreme Court Leaker That Never Was | This Term's 1st Opinion | Attorney-Client Privilege

On a busy Monday, the justices chose not to address an attorney-client privilege issue and handed down their first opinion of the term.
9 minute read
December 27, 2022 | New York Law Journal

Tax Court Rules That Loan With Appreciation Interest Is Respected as Debt

When an instrument denominated as debt has "equity-like" features, should it be respected as debt or recharacterized as equity for income tax purposes? In this edition of their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss a recent opinion from the Tax Court which came to a "taxpayer-friendly result" on this issue.
4 minute read
December 14, 2022 | New York Law Journal

Successor Liability for Taxes: 'ACI Construction'

The potential for enforcement of a transferor's tax obligations against its transferee is demonstrated by 'ACI Construction, LLC v. United States', a recent decision of the U.S. District Court for the District of Utah.
7 minute read
December 06, 2022 | New York Law Journal

'Pilaro' Provides Additional Guidance on the Meaning of Permanent Place of Abode

The Tax Appeals Tribunal recently ruled in favor of a taxpayer in 'Matter of Joseph Pilaro and Joe Gorrie' concerning a petitioner who leased an apartment for part of a year, and later owned (but did not occupy) another apartment, in Manhattan.
7 minute read
November 07, 2022 | The Recorder

Meet the Winners of the California Legal Awards

The Recorder is proud to announce this year's winners for the California Legal Awards, celebrating the achievements of lawyers and companies leading technology, innovation and the profession as a whole.
4 minute read

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