The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
In Soroban Capital Partners v. Commissioner, the United States Tax Court determined that entities formed as state law limited partnerships did not necessarily mean that the limited partnerships’ limited partners were limited...more
The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more
In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more
2023 saw a number of key tax developments that may affect the private fund industry going into 2024, from key US Tax Court opinions and updates to Internal Revenue Service (IRS) Forms, to new regulations proposed by the IRS...more
Certain limited partners in venture capital and private equity will likely see an increase in their tax liability due to a recent U.S. Tax Court decision. Generally, partners in a partnership and members in a limited...more
The challenges in establishing protection under Public Law 86-272 (“P.L. 86-272”) were on display in a recent decision of the Minnesota Tax Court. Uline, Inc. v. Commissioner of Revenue, Minn. Tax Court, No. 9435-R (June 23,...more
Summary: Commonwealth challenges the IRS’s denial of application for tax exemption under 501(a), claiming, by submission for declaratory judgment, to be an organization described in section 501(c)(15). Commonwealth was...more
The annual gift tax exclusion amount has increased for the second straight year. The IRS raised the exclusion amount for 2023 to $17,000 per recipient, up from $16,000 per recipient in 2022. In the recent past, adjustments...more
Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more
Can and should your religious organization seek church status with the IRS? A look at a few pros, cons, and due diligence considerations....more
Tax Litigation: The Week of February 21, 2022, through February 25, 2022 Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23, 2022 | Nega, J. | Dkt. No. 11308-18 Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23,...more
The Tax Court in Brief February 14 – February 18, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
TRANSACTION PRIVILEGE TAX UPDATES LEGISLATION - Senate Bill 1110, Chapter 443. Tribal Exemptions. This bill codified the following exemptions applicable to Indian tribes and tribal members at A.R.S. § 42-5121 et seq.: (1)...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of May 3 – May 7, 2021 - Chancellor v. Comm’r, T.C. Memo....more
On May 17, 2021, the U.S. Tax Court issued a Memorandum Opinion in Vincent J. Fumo v. Commissioner, T.C. Memo. 2021-61, regarding the definition of a “disqualified person” under I.R.C. section 4958(a)(1). Managers of...more
Name: McClain Museum, Inc. v. Madison County Assessor - Date Issued: November 7, 2019 - Property Type: Museum - Assessment Year: 2014...more
There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more
The Indiana Tax Court in Lake County Trust Co., Trust No. 6 v. St. Joseph County Assessor on October 17th reversed the dismissal of an exemption appeal by a 501(c)(3) non-profit, Flowers for Heaven, Inc., operating a pro-life...more
Campus Real Estate, Property Management, Tax Credits The 15th Annual Higher Education Real Estate Lawyers conference was held in San Francisco, where attendees listened to and learned from both in-house and outside counsel at...more
In a recent tax court case, Holy Trinity Baptist Church v. City of Trenton (Docket No. 015909-2014, February 2, 2017), the court overturned the findings of the County Board of Taxation and upheld the tax exemption for...more
On September 30, 2016, the Connecticut Supreme Court heard oral argument in Nutmeg Housing Development Corp. v. Colchester. On the face of it, the ad valorem valuation of a garden variety property in the suburbanizing Town...more
In many family law settlements, whether they are obtained voluntarily through an agreement or the result of litigation ending in a court order, certain provisions are made for minor children, including the support of the...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
Court Of Appeals Affirms Revocation Of Tax Exemption For Public Parking Facilities - Reversing a decision by the Appellate Division, the Court of Appeals has held in a 5-2 decision that a charitable organization is not...more
On June 25, 2015, a New Jersey Tax Court issued a significant opinion in the case of AHS Hospital Corp. d/b/a Morristown Memorial Hospital v. Town of Morristown, upholding the Town of Morristown’s denial of Morristown...more