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April 17, 2024 | New York Law Journal

Sham Stock Sales: 'Acqis Technology v. Commissioner'

'Acqis Technology v. Commissioner' confirms the continued vitality of the doctrine in the context of an apparent scheme to evade tax with respect to proceeds attributable to the settlement of patent infringement claims.
9 minute read
February 29, 2024 | Legaltech News

Tracking Generative AI: How Evolving AI Models Are Impacting Legal

A running compilation of how the legal landscape continues to be shaped by generative AI tools, from GPT technologies to art generation tools and beyond.
146 minute read
February 27, 2024 | New York Law Journal

Tax Court Order Raises Substance-Over-Form Questions

Whether an LLC is treated as a partnership or a disregarded entity for federal income tax purposes can sometimes have a significant effect on the tax consequences of a transaction. A recent order issued by the Tax Court in Joint Star Properties, LLC v. Commissioner illustrates the sorts of issues that can arise.
6 minute read
February 14, 2024 | New York Law Journal

Intercompany Loans Recharacterized: 'Fry v. Commissioner'

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
December 26, 2023 | New York Law Journal

Here Comes the Sun: New Solar Tax Credit Rules Benefit Rental Property Owners

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.
5 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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December 20, 2023 | New York Law Journal

Transferee Liability Under New York Law: 'Dillon Trust Co. v. United States'

Under some circumstances, sellers of stock of a corporation may be liable as transferees for corporate obligations arising before or in connection with the closing. In 'Dillon Trust Co. v. United States', the Court of Federal Claims concluded that the sellers of the stock of two corporations were liable for tax obligations of the corporations attributable to sales of assets for notes prior to the closing of the stock sale.
9 minute read
December 13, 2023 | Law.com

How Some Big Law Firms Can Afford Associate Salary Raises: The Morning Minute

The news and analysis you need to start your day.
4 minute read
December 05, 2023 | Daily Report Online

Big Law's Flood Into Booming Nashville Tests Client Loyalties

"Some clients are super loyal to their firms that they work with, sometimes blindingly so," said Joan MacLeod Heminway, a University of Tennessee law professor.
9 minute read
December 05, 2023 | The American Lawyer

Big Law's Flood Into Boomtown Nashville Tests Client Loyalties

"Some clients are super loyal to their firms that they work with, sometimes blindingly so," said Joan MacLeod Heminway, a University of Tennessee law professor.
9 minute read
December 01, 2023 | New York Law Journal

New York Should Reevaluate Suspension of Driver's Licenses for Tax Collections

As this column has frequently highlighted, the New York Division of Taxation is not afraid to pursue aggressive positions in order to assess and collect revenue for the state. However, many taxpayers may be unaware of one of the more potent tools at the disposal of the division: the ability to suspend a taxpayer's driver's license for non-payment of substantial back taxes.
8 minute read

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