Administrative Agency Tax Conflict of Laws

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The trust decanting statutes: Nuisances that should be repealed.

Inherent in a trustee’s discretionary authority to make a distribution of trust property outright and free of trust to a permissible beneficiary of the trust may well be the authority to distribute the property instead to...more

Investment Management Legal + Regulatory Update: February 2012

In this issue: Senate Bill Would Raise Taxes on Derivatives Trades; Senate Hearings Question Fund Investments in Commodity-related Investments; SEC Grants No-action Relief for Potential Section 10(f) Violations; FINRA...more

Ninth Circuit Reverses Tax Court on Including Stock Option Costs in Cost-Sharing Agreement: A Tale of Two Regulations

On May 27, in a 2-1 panel decision, the Ninth Circuit Court of Appeals reversed the United States Tax Court in Xilinx, Inc. v. Commissioner and remanded on two specific issues. The Ninth Circuit held that, under Treasury...more

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