Court cases, judgements and ongoing coverage of tax topics with a legal perspective
By Jeremy H. Temkin | September 13, 2023
This column examines an emerging split over the treatment of 26 U.S.C. §6213(a), which provides taxpayers seeking relief from deficiencies found by the IRS with 90 days to file their Tax Court petitions.
10 minute read
By Juliya L. Ismailov | September 10, 2023
There has been an inflection point in the economy as a result of work life returning to a new post-pandemic normal. These changes are, in turn, impacting employees' choice of domicile for trust and estate planning purposes, among other things. In this article, Juliya L. Ismailov explores the far-flung tax consequences of post-pandemic recovery.
7 minute read
By Sharon L. Klein | September 10, 2023
The first year of the 2023-2024 legislative session began Jan. 4, 2023 and ended June 8, 2023. In this article, Sharon L. Klein highlights some of the most significant developments.
15 minute read
By Barry Black and Christopher Byrnes | August 30, 2023
Counseling a religious entity is different from advising other not-for-profit corporations due to the special rules applicable to, and the constitutional protections afforded to, religious organizations in the United States.
8 minute read
By Sidney Kess | August 28, 2023
In this article, Sidney Kess discusses the various potential tax issues to consider when businesses and individuals relocate to a different state.
6 minute read
By Jessie Yount | August 28, 2023
Michael Lebovitz, the co-head of the international tax and transfer pricing team at Mayer Brown, joined Eversheds as it builds its San Francisco presence.
3 minute read
By Conrad Teitell | August 27, 2023
This article covers how an estate planning organization was found to not qualify for federal income tax exemption under IRC §501(a) as an organization described in IRC §501(c)(3).
8 minute read
By Ezra Dyckman and Charles S. Nelson | August 22, 2023
The distinction between COD income and gain on the sale of property was at issue in a recent Tax Court case, Parker v. Commissioner, discussed here.
4 minute read
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
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Professional Announcement
Frederick D. Miceli has joined the firm as Of Counsel
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