Our Tax Group reviews how the U.S. Supreme Court’s ruling in Loper Bright that overturned many decades of the Chevron doctrine will affect federal and state taxes....more
If the IRS challenges the tax-exempt status of a name, image, and likeness (NIL) collective, the collective must understand how best to respond. Our Federal Tax Group details what NIL collectives need to know to make the cut....more
The Inflation Reduction Act Strategic Operating Plan, released last week by the Internal Revenue Service, envisions a future of increased audits and penalties for family offices, high-wealth individuals, large partnerships,...more
Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling. ...more
Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more
5/25/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums....more
Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed...more
At long last, we have the first set of final regulations for the Tax Cuts and Jobs Act. Our International Tax Group celebrates with a look at how the Treasury and IRS have clarified Section 965 and why taxpayers may need to...more
With tax reform on the horizon, Treasury takes aim at three sets of regulations with clear cross-border implications. Our International Tax Group explains the department’s recommendations to scrap much of Section 385 and...more
LTR 201542004 at first seems to involve a standard spinoff for the purpose of pursuing a reverse Morris Trust combination of Controlled with a Merger Partner, with the “significant issue” for ruling being a proposed swap of...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more
9/2/2015
/ Business Assets ,
Capital Gains ,
Commercial Real Estate Market ,
Cross-Border Transactions ,
Foreign Affiliates ,
Goodwill ,
Intangible Property ,
Real Estate Investments ,
Related Parties ,
Section 1031 Exchange ,
Tax Planning