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The American Lawyer

Kirkland Strikes Back in Paul Weiss Talent Battle, Also Adding Weil and Sidley Partners

Debt finance partner Paul Sandler arrived from Paul Weiss, Kirkland announced on Wednesday, alongside an insurance M&A partner from Sidley Austin and two real estate tax lawyers from Weil Gotshal.
2 minute read

The Recorder

Fennemore Merges With Sacramento-Based Tax Firm

The merger is the firm's third combination of 2024.
3 minute read

New Jersey Law Journal

The Risks and Rewards of Becoming a Shareholder

"Whether one represents the employer or the employee, counsel is wise to consider the legal, tax, and any other consequences that follow when an employee of a corporation or an LLC is to become a co-owner of the entity," writes Stuart Pachman of Brach Eichler.
5 minute read

Daily Business Review

Fort Lauderdale Litigators Beat $21M in IRS Penalties for Texaco Heiress

The jury deliberated for less than 45 minutes, defense counsel said.
4 minute read

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

New York Law Journal

Disputes and Consequences

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

The American Lawyer

Orrick Hires Greenberg Traurig Energy Renewables Shareholder in Chicago

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

National Law Journal

IRS Seizure of Crypto Records Sets Up Privacy Rights Showdown at 1st Circuit

Appeals court will consider whether investors have a reasonable expectation of privacy in information they provide to a cryptocurrency exchange platform.
6 minute read

New Jersey Law Journal

New Jersey Strikes Back With New Convenience of the Employer Rule

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

New York Law Journal

The Impact of the CCAM on Trust Decanting in New York

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

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