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Litigation Daily

Litigators of the Week: Eliciting a Mea Culpa From the IRS For Citadel Founder Over Leaked Tax Records

After William Burck, AJ Merton and Peter Fountain of Quinn Emanuel sued the Internal Revenue Service on behalf of billionaire investor Ken Griffin, the agency this week apologized to him and thousands of others whose tax information was leaked to the press by a contractor.
10 minute read

National Law Journal

FAA Privacy Law for Private Jets Won't Stop Taylor and Elon From Popping Up on IRS's Radar

Section 803 of the FAA Reauthorization Act of 2024, signed into law last month, requires the FAA to establish "a process by which, upon request of a private aircraft owner or operator, the administrator withholds the registration number and other similar identifiable data or information ... for the noncommercial flights of the owner or operator."
7 minute read

New York Law Journal

Strategic Estate Planning Before 2026 BEA Change Can Protect Taxpayer Assets from Gift and Estate Tax

In 2017, Congress enacted the Tax Cuts and Jobs Act, doubling the estate and gift tax exemption. This increase is set to expire on Jan. 1, 2026, reverting to pre-TCJA levels. Taxpayers should understand strategies to take advantage of the increased exemption before it expires to shield their assets from future gift and estate taxes. Stephen L. Ferszt, chair of Olshan Frome Wolosky's Employee Benefits Practice discusses the complex landscape of estate planning and the critical decisions taxpayers need to make before the BEA rollback takes effect.
5 minute read

New York Law Journal

Unpacking ANNY, NYC's New Affordable Housing Tax Exemption Program

After two long years since the "lapse" of New York's 421-a program, real estate developers may finally be able to breathe a sigh of relief, as the new ANNY program will bring many of the same real property tax benefits for providing affordable housing.
7 minute read

New York Law Journal

Stretching IRA Payments for Heirs: Using Charitable Remainder Unitrusts

The SECURE Act—starting in 2020— killed the stretch IRA for most heirs. Until that legislation, an heir could generally have required minimum distributions stretched over his or her life expectancy. And that minimized taxes—plus; the assets in the heir's IRA grew tax-free until withdrawn.
5 minute read

National Law Journal

Supreme Court Upholds Repatriation Tax on Foreign Earnings

In their 7-2 decision, the justices rejected arguments that the Mandatory Repatriation Tax violates the Constitution's Apportionment Clause, which requires "direct" taxes be divvied up among the states based on population.
5 minute read

New York Law Journal

Theft Loss Deductions Denied

In two recent Tax Court decisions, it was determined that, although there had been a loss in value attributable to activities ultimately determined to be crimes, no theft loss was allowable to the petitioners because no crime in the nature of theft had been committed against the petitioners themselves to deprive them of property that they owned.
9 minute read

New Jersey Law Journal

How Will the Federal Reclassification of Marijuana Affect New Jersey's Cannabis Industry?

"After nearly 55 years, it appears the federal government is catching up with the times and will recognize that marijuana has an accepted medical use," write Michael F. Schaff and Jennie M. Miller.
7 minute read

National Law Journal

Justices Stick Estate With High Tax Bill Over Life Insurance Policy

The U.S. Supreme Court's decision "upsets the assumptions of many practitioners that the proceeds of life insurance used to redeem a deceased shareholder are not factored into the estate tax calculation," said tax attorney Joel Carpenter.
4 minute read

The Legal Intelligencer

Minimizing Tax Cost in Shutting Down a Captive Insurance Company

With careful planning, substantial tax liability can often be avoided in making a former captive's assets available to meet future business needs of related entities.
7 minute read

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