Monthly Minute | January 2020
It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more
Under a Last Will and Testament, a decedent disposes of both their tangible personal property as well as their intangible personal property. Questions might arise in the context of administering an Estate, however, as to...more
Don’t Do It- There are certain generally accepted “dos and don’ts” of which almost every investor is certainly aware. For example, do not put all your eggs in one basket; if an investment seems too good to be true, stay...more
The IRS issued Proposed Regulation 117589-18 on June 11, 2020 (the “Proposed Regs”), in response to legislative changes applicable to like-kind exchange transactions (“1031s”). The Proposed Regs address transactions involving...more
The Washington Department of Revenue (DOR) on May 28, 2020, published a Special Notice advising that beginning June 1, 2020, in determining a decedent’s taxable estate for Washington estate tax purposes, the DOR will treat a...more
In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No. 01-19-00216-CV, 2020 Tex....more
In a significant victory for policyholders, the United States District Court for the District of Maryland recently determined that certain ransomware-related losses are covered under language commonly found in traditional...more
• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more
Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more
The Kingdom of Saudi Arabia is a nation with a vast and growing population of over 30 million people and significant requirements for soft and hard infrastructure. Historically, the responsibility for procuring this...more
In a rare special meeting on February 24, 2017, the Multistate Tax Commission (MTC) adopted amendments to the MTC’s Model General Allocation and Apportionment Regulations (Model Regulations) that it has worked on since 2014....more
The California Franchise Tax Board (FTB) will hold a second Interested Parties Meeting at their office in Rancho Cordova on April 20, 2016, dealing with the apportionment of income for combined reporting groups with both...more
On September 16, 2015, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) published proposed regulations under section 367 and proposed and temporary regulations under section 482 that together would...more
The Multistate Tax Commission’s (MTC) Annual Conference and Committee Meetings are being held on July 27-30, 2015, in Spokane, Washington. On Tuesday, July 28, 2015, at approximately 1:00 pm PDT (exact time subject to...more
In the pre-Facebook era, the word “like” was primarily a verb (and an interjection sprinkled throughout valley girls’ conversations). Although you could have likes and dislikes in the sense of preferences, you could not give...more
Hotels are one of the most misunderstood properties when valued by local assessors for property tax purposes. A hotel’s enterprise activity is comprised of tangible property, in the form of real estate and personal property,...more
As businesses move away from paper documents, courts are poised to broaden ‘conversion’ definition. The fundamental shift for businesses in the past 15 years from paper documents to computer data has forced the courts...more
On December 18, 2012, the California Court of Appeal ruled that receipts from the right to replicate software are sourced as sales “other than tangible personal property.” In reversing the trial court, the Court of Appeal...more