New York Law Journal | Analysis
By David E. Kahen and Elliot Pisem | February 14, 2024
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.
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."
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.
National Law Journal | Analysis
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.
New Jersey Law Journal | Commentary
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.
New York Law Journal | Analysis
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?
New York Law Journal | Analysis
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.
New York Law Journal | Analysis
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.
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.
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.
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