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Court cases, judgements and ongoing coverage of tax topics with a legal perspective
By Jeffrey A. Galant | August 21, 2023
Likely, either the partnership or limited liability company is the most flexible of entities now available for business- or investment-related ventures. Whether either such entity is a partnership for tax purposes is the subject of this note.
7 minute read
By Elliot Pisem and David E. Kahen | August 16, 2023
The article discusses a recent Tax Court order in Computer Sciences Corporation v. Commissioner. The order, after discussing various issues raised by the government relating to substance over form, step transactions, nonqualified preferred stock and other matters, denied a motion by the petitioner for summary judgment that it was entitled to a large capital loss.
9 minute read
By Todd Kesterson and Alyssa R. Wan | August 15, 2023
As more donor groups have formed name, image and likeness (NIL) collectives as not for profit entities, the Internal Revenue Service (IRS) recently released guidance that effectively puts the brakes on the ability of these entities to collect tax-deductible donations from supporters. This guidance also raises compliance concerns for NIL collectives and possibly other charities.
7 minute read
By Stephen McNally and Paige M. Bellino | August 8, 2023
While 'Tyler' would at first blush seem to have a localized effect, the ripples are already being felt in New Jersey, which utilizes a similar tax sale system as the one used in Minnesota.
6 minute read
By Ellen Bardash | July 26, 2023
The pause in evaluating the deal was welcomed by groups which on Tuesday filed amicus briefs with the court, asking U.S. District Judge Maryellen Noreika to ask for and consider more details on how it was reached.
3 minute read
By Sidney Kess | July 26, 2023
The middle of the year is a good time to be certain that each individual's situation has been evaluated so that planning can be custom-tailored to each client's unique situation.
8 minute read
By Brenda Sapino Jeffreys | July 21, 2023
Partners in Texas continue to move from one Big Law firm to another, as lateral hiring continues at a fast clip.
3 minute read
By Alexander Lugo | July 20, 2023
"We've been focusing on cross-border work all these years ... and I think it's more important than ever now," said incoming partner Summer LePree. "Almost everything has a cross-border component now."
3 minute read
By Amanda O'Brien | July 19, 2023
Paul Fuener joined the firm's legacy liability practice in Pittsburgh, while Matthew Schnall joined the tax practice in Boston.
4 minute read
By Jeremy H. Temkin | July 19, 2023
This column discusses the court's decision in Polselli, Justice Jackson's concurring opinion, and the potential for future challenges to the IRS's issuance of summonses without notice.
10 minute read
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