Court cases, judgements and ongoing coverage of tax topics with a legal perspective
By Patricia Kane | February 12, 2024
A discussion of disputes and their consequences in tax law. The author writes: "Well-settled in the tax law is the notion that the character of amounts received in the settlement of a claim turns on the underlying nature of the claim."
8 minute read
By Brenda Sapino Jeffreys | February 5, 2024
Greenberg Traurig shareholder Alejandra Garcia Earley, who focuses on project finance and energy tax equity financings, has joined Orrick Herrington & Sutcliffe's energy and infrastructure team as a partner in Chicago.
3 minute read
By Avalon Zoppo | February 2, 2024
Appeals court will consider whether investors have a reasonable expectation of privacy in information they provide to a cryptocurrency exchange platform.
6 minute read
By Jason Feingertz, Katherine Gallagher and Zach Roop | January 29, 2024
States have long grappled with the question of how to properly source the income of an employee who works at home in one state, for an employer in another state. In response to the tax burden placed on its residents and the tax revenue it was losing, in 2023 New Jersey passed its own Convenience of the Employer Rule.
5 minute read
By Joseph T. La Ferlita and Nicholas G. Moneta | January 26, 2024
On Dec. 29, 2023, the Office of the Chief Counsel of the IRS released Chief Counsel Advice Memorandum 202352018 (the CCAM). Although some have commented on the CCAM's impact on trust modifications, a further question is what impact, if any, will the CCAM have on trust decantings in New York?
8 minute read
By Alison Powers Herman and Karen T. Schiele | January 26, 2024
Transferring assets to an intentionally defective grantor trust (IDGT) is a potentially powerful estate planning technique, allowing an individual to pass significant value to his or her intended beneficiaries transfer tax-free.
8 minute read
By Susan Rothwell | January 26, 2024
The purpose of this article is to alert practitioners to how easily a foreigner's New York estate can be compelled to bring a proceeding in a New York Surrogate's Court and owe federal (and sometimes state) estate taxes, all of which add significant expense and delays before beneficiaries can receive the New York property.
9 minute read
By Brenda Sapino Jeffreys | January 22, 2024
King & Spalding hired a Bechtel Energy energy and construction lawyer as a partner in Houston, and Bracewell hired a lawyer with experience in energy transition tax credits as a partner in Houston.
4 minute read
By Alex Anteau | January 19, 2024
Plaintiffs, represented by Lindsey Hillis of the Hillis Firm and Jonathan Palmer of Knight Palmer, refer to the Fulton County Board of Tax Assessor's tactic as "sales chasing, arguing that Georgia's courts have already found the process illegal on several occasions.
4 minute read
By Jeremy H. Temkin | January 17, 2024
Over the past year, federal courts have issued decisions clarifying the extent to which §6103 shields tax returns and return information from disclosure in civil litigation, the extent to which the IRS is permitted to disclose confidential information during and in connection with investigations, and the application of a safe harbor shielding the government from liability for unauthorized disclosures.
10 minute read
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