New York Law Journal | Analysis
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.
By Philip Wagman, Chair, Tax Section | January 16, 2024
Philip Wagman, chair of the Tax Section, writes: The Tax Section provides members with opportunities to research and learn more about these tax issues and a host of other current developments in the tax law.
The Legal Intelligencer | Commentary
By Mark L. Lubin | January 16, 2024
Now is a good time for partnerships and their partners to take steps to mitigate the potential consequences of the audit changes, and to anticipate potential legislative developments.
By Ezra Dyckman and Charles S. Nelson | December 26, 2023
Ezra Dyckman and Charles Nelson discuss the Inflation Reduction Act, which has expanded the scope of green energy tax credits, and also proposed regulations by the Treasury Department that have the potential to allow even taxpayers with no income tax liability to more easily monetize some of these tax credits.
New York Law Journal | Analysis
By Conrad Teitell | December 22, 2023
In his Estate Planning and Philanthropy column, Conrad Teitell reflects on the Tax Reform Act of 1969, as he has been doing in recent years during the month of December, and shares a memory associated with the subject.
New York Law Journal | Analysis
By David E. Kahen and Elliot Pisem | December 20, 2023
Under some circumstances, sellers of stock of a corporation may be liable as transferees for corporate obligations arising before or in connection with the closing. In 'Dillon Trust Co. v. United States', the Court of Federal Claims concluded that the sellers of the stock of two corporations were liable for tax obligations of the corporations attributable to sales of assets for notes prior to the closing of the stock sale.
Connecticut Law Tribune | News
By Emily Cousins | December 15, 2023
"The fact that Alico is subject to multiple taxation as a result of its decision to register its vehicles in Massachusetts and to garage them in Somers does not render § 12-71 (f) discriminatory," the opinion said.
New York Law Journal | Analysis
By Erica F. Buckley | December 8, 2023
It would make sense for a nonprofit in New York City to understand the benefits of leasehold condominiums and the value of the 420-a Exemption. This is especially true if your nonprofit operates a homeless shelter, which, per the DOF, is a nonresidential purpose entitling your organization to robust tax relief.
By Colleen Murphy | December 7, 2023
"In light of the implication of the clear constitutional ruling in 'Tyler,' that the forfeiture of a property owner's equity above the tax amount owed constitutes a prohibited taking, we now review New Jersey's TSL statutory framework," Judge Lisa Perez Friscia wrote for the court. "We are guided by the United States Supreme Court's charge that 'the taxpayer must render unto Caesar what is Caesar's, but no more.'"
By Jimmy Hoover | December 5, 2023
"[W]hen the court opens a door, Congress tends to walk through it," Justice Neil Gorsuch said.
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