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Administrative Procedure Act Tax Planning

Gerald Nowotny - Law Office of Gerald R....

Old Days – Memories of Equity Split Dollar in the Post-Loper Bright Era

This article focuses on the impact of the U.S. Supreme Court in Loper Bright Enterprises v. Raimondo, 603 U.S. (2024) and how it might apply to Split Dollar life insurance and possibly resurrect one of my favorite life...more

Freeman Law

Texas Comptroller Procedure | Audits and Assessments

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Receiving an assessment from the Texas Comptroller can be overwhelming, and not just from a financial perspective. To a taxpayer with little to no experience in dealing with the Comptroller’s office, even knowing how to...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Freeman Law

Tax Court in Brief | Green Valley Investors v. Comm’r (consolidated) | Notice 2017-10 Deemed Improperly Issued; Syndicated...

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Tax Litigation: The Week of November 7th, 2022, through November 11th, 2022 Fields v. Comm’r, T.C. Summary Opinion 2022-22 | November 10, 2022 | Panuthos, Special Trial J. | Dkt. No. 2925-20S (IRS Automated Underreporter,...more

Polsinelli

Big Win for Investors Facing Listed Transaction Penalties for Conservation Easements

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On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more

Polsinelli

SCOTUS Could Vacate Conservation Easement Regulations

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As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more

Freeman Law

Court Declares IRS Micro-Captive Notice 2016-66 Unlawful: What Taxpayers Should Do Now

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Introduction.  On May 17, 2021, the United States Supreme Court handed the IRS a significant loss when it concluded that CIC Services, LLC (“CIC”) could continue its lawsuit against the IRS for violations of the...more

Freeman Law

The Art of an IRS APA Defense: Conservation Easements and Hewitt

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Good tax attorneys will do whatever it ethically takes to win on behalf of their clients.  Often, this means the attorney must not only have a good understanding of the substantive provisions at play, but also relevant...more

Sullivan & Worcester

A Warm Welcome to the Tax Trotter

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Happy New Year and welcome to the Tax Trotter! What a year 2020 has been! Stock markets running high, travel low, Zoom reigning supreme with the blue light eyeglass filter becoming as popular as the anti-glare...more

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