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Court cases, judgements and ongoing coverage of tax topics with a legal perspective
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?
8 minute read
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.
8 minute read
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.
9 minute read
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.
4 minute read
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.
4 minute read
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.
10 minute read
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.
3 minute read
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.
5 minute read
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.
5 minute read
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.
2 minute read
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