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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

New York Law Journal

IDGTs: Flexible Drafting Saves the Day When Intended Benefits Become a Burden

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.
8 minute read

New York Law Journal

Unpleasant Surprises When a Foreign National Dies Owning Property in New York

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.
9 minute read

Texas Lawyer

Bracewell, King & Spalding Grow Energy Teams With In-House Adds

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.
4 minute read

Daily Report Online

'Either it Was Legal or It Was Not': Appellate Court Says Class Certification Can Move Forward in Metro Atlanta Property Tax Dispute

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.
4 minute read

New York Law Journal

Tax Return Confidentiality: Recent Developments

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.
10 minute read

New York Law Journal

Staying On Top of Tax Law Changes and Guidance

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.
3 minute read

The Legal Intelligencer

Tax Treatment of Partnership and Their Partners—Are Rough Times Ahead?

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.
5 minute read

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