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  • Article

    Still Waiting For Guidance On Material Participation

    In the Frank Aragona Trust case, the tax court disagreed with the Internal Revenue Service’s arguments that a trust was incapable of providing "personal services" to meet the material participation test under IRC § 469 (c)(7).
    United StatesTax
    BakerHostetler
    BakerHostetler
  • Article

    Stock Sale With An Asset Basis Step Up: New Alternative To The Section 338 Election

    The Internal Revenue Service recently issued final regulations under Internal Revenue Code section 336(e) which provide for an election to treat certain qualified stock dispositions as asset sales, similar to a Section 338(h)(10) Election.
    United StatesTax
    Kilpatrick Townsend & Stockton LLP
    Kilpatrick Townsend & Stockton LLP
Article

Structuring Investments Into The U.S.

Private Wealth attorneys Katie Gerber and Brooke Elliott hosted the eighth session in our International Private Client Webinar Series.
United StatesTax
Holland & Knight
Holland & Knight
  • Article

    Success-Based Fees: Elect The Safe Harbor Or Document Thoroughly

    When taxpayers pay fees contingent on the successful closing of certain "covered transactions," including, for example, taxable acquisitions of assets that constitute a trade or business, ...
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Supreme Court Denies Certiorari In Historic Boardwalk Hall

    The Supreme Court on May 28 declined to hear the appeal of a historic rehabilitation tax credit partnership that claimed the Third Circuit Court of Appeals erred when it held the partnership’s private-sector equity investor was not a bona fide partner and could not claim the rehabilitation tax credits.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    T&E Litigation Update: "Cushman v. Folan"

    In "Cushman v. Folan", Case No. 09-P-894, 2010 Mass. App. Unpub. LEXIS 1135 (Oct. 19, 2010), a decision issued pursuant to Rule 1:28, the Appeals Court addressed the procedural question of whether an appeal of a fees award in probate court was properly dismissed with respect to one of the appellants ("Cushman") for her failure to post a bond to secure the judgment, as ordered by the probate court.
    United StatesTax
    Day Pitney LLP
    Day Pitney LLP
  • Article

    T&E Litigation Update: "Victor v. Massachusetts Executive Office of Health & Human Services" and "Carrison v. Smiddy"

    In "Victor v. Massachusetts Executive Office of Health & Human Services", Case No. 09-P-1361, 2010 Mass. App. Unpub. LEXIS 844 (July 21, 2010), a decision issued pursuant to Rule 1:28, the Appeals Court affirmed a denial of Medicaid benefits on the grounds that a family trust established by the plaintiff's husband is a Medicaid-qualifying trust.
    United StatesTax
    Day Pitney LLP
    Day Pitney LLP
  • Article

    Tax Bar Has Serious And Substantial Comments To The Proposed IRC Section 385 Regulations

    The Proposed Regulations have been met with substantial criticism by the tax bar and taxpayers alike.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    Tax Court Addresses Related Party Rules As Applied For S Corporation Employees Participating In An ESOP

    In Petersen v. Commissioner, 148 T.C. No. 22 (June 13, 2017), the Tax Court addressed the application of Section 267(a)(2) to an S corporation that maintains an employee stock ownership plan (ESOP).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Tax Court Holds NOL Attribute Reduction Must Be Treated On A Consolidated Basis

    Ultimately, the Tax Court rejected Marvel's arguments that the plain language of Section 108 proved that Congress intended that consolidated groups use a separate-entity approach.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Tax Court Rules Certain Discounts Not Deductible Until Redeemed

    In a recent decision, the Tax Court held that discounts redeemable only against future purchases were deductible when redeemed rather than when earned by the taxpayer’s customers.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    Tax Cuts And Jobs Act Of 2017 – Unreimbursed Partner Expenses

    The passage of the Tax Cuts and Jobs Act of 2017 ("TC&JA") has increased the planning importance of so-called "unreimbursed partner expenses" for members of partnerships and LLCs treated as partnership.
    United StatesTax
    Dickinson Wright PLLC
    Dickinson Wright PLLC
  • Article

    Tax-Free Employee Educational Assistance Programs Extended by Fiscal Cliff Legislation

    At the end of last year, we alerted you that the beneficial tax treatment of educational assistance programs under Section 127 of the Internal Revenue Code (the Code) pursuant to which an employer pays, or reimburses, an employee for up to $5,250 in educational assistance was set to expire on December 31, 2012 and it was unclear whether Congress would act to extend it.
    United StatesTax
    Patterson Belknap Webb & Tyler LLP
    Patterson Belknap Webb & Tyler LLP
  • Article

    Tax Insights: Preparing For ASU 2023-09 Income Tax Disclosures

    The Accounting Standards Update (ASU) 2023-09, issued by the Financial Accounting Standards Board (FASB)...
    United StatesTax
    Riveron
    Riveron
  • Article

    Tax Proposals Bid Adieu To Carried Interest

    On February 6, 2025, the Trump Administration announced various tax and budgetary priorities discussed further here, including closing the "carried interest loophole." On the same day...
    United StatesTax
    Hogan Lovells Cadwalader
    Hogan Lovells Cadwalader
  • Article

    Tax Reform: UBTI Guidance On Qualified Transportation Fringe Benefits

    From Proskauer's Not For Profit / Exempt Organization Blog, a discussion of recent IRS guidance and New York State legislative relief on Internal Revenue Code 512(a)(7)
    United StatesTax
    Proskauer Rose LLP
    Proskauer Rose LLP
  • Article

    Taxation: New Jersey Appellate Division Court Rules That Qui Tam Awards Are Taxable Under The New Jersey Gross Income Tax Act

    The plaintiff, a financial consultant, discovered fraudulent Medicare billing practices by some of his clients.
    United StatesTax
    Arnold & Porter
    Arnold & Porter
  • Article

    Taxpayers May Not Prepay Income Tax To Avoid Cap On SALT Deduction

    The federal tax reform package recently approved by Congress (the Bill) contains a cap on the state and local tax deduction that may be claimed by individuals on their federal income tax returns.
    United StatesTax
    McDermott Will & Emery
    McDermott Will & Emery
  • Article

    The Augusta Rule: Sweeping Up The Greens

    The Augusta Rule is a lesser-known tax strategy despite its relatively simple structure and effective results.
    United StatesTax
    EPGD Business Law
    EPGD Business Law
  • Article

    The Changing Pennsylvania Tax Landscape For Remote Work

    Businesses with employees in Pennsylvania should be prepared to adapt to a post-COVID-19 world now that temporary guidance regarding remote work has expired and pre-pandemic rules regarding...
    United StatesTax
    Ballard Spahr LLP
    Ballard Spahr LLP
  • Showing 521–540 of 8619 results

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