Let's Talk About the Anatomy of a Prenuptial Agreement
Advancing Agriculture: Security Interests and Article 9 Challenges (Part 2)
California’s Existing Partial Exemption for Statewide Sales and Use Tax Paid on Qualified Tangible Personal PropertyRTC section 6377.1 exempts from certain state sales and use taxes the sale of, and the storage, use or other...more
This Insights blog is Part 2 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”)....more
The IRS sends a CP504 Notice when a taxpayer has failed to pay a balance owed. The CP504 Notice is a Notice of Intent to Levy issued pursuant to Section 6331(d) of the Internal Revenue Code. If a taxpayer fails to make...more
In the international tax context, the source of a taxpayer’s income can have significant implications. The source of income may determine whether a taxpayer qualifies for a foreign tax credit with respect to the income. Or,...more
In a US District Court complaint filed May 26, 2021, a married couple is seeking a refund of taxes they paid on cryptocurrency tokens the husband created, asserting that current law does not permit the treatment of created...more
“Yeah, I’m the Tax Man” Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more
Since 2017, the California Franchise Tax Board has been working on revisions to its regulations for market-based sourcing regulation for income from services and intangibles and for petitioning for alternative apportionment....more
As previously reported, in Ex parte Russell County Community Hospital, the Alabama Supreme Court announced that all software, including customized software created for a particular user, is "tangible personal property" and...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
The IRS has published a Revenue Ruling and FAQs clarifying some long-standing virtual currency questions. On October 9, 2019, the US Internal Revenue Service (IRS) issued its first guidance on the tax treatment of...more
Within the past year, the IRS has not changed its position on the way they are treating the taxation and reporting of digital token transactions. This alert serves as an update to last year’s rundown of cryptocurrency...more
As previously reported, during the recent legislative session the Alabama Legislature finally resolved the so-called “Moody Issue,” named after the taxpayer victory in Moody v. Alabama Department of Revenue, regarding the...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
New York’s legislature has been in the news lately after having “rotated an avian creature through more than 90 degrees” at Congress in response to the limitations passed under the Tax Cuts and Jobs Act on the deduction of...more
The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation....more
In this first of (we hope) many posts on the interesting and myriad tax issues arising in the world of cryptocurrency and blockchain technology, we focus on the very basic U.S. federal income tax consequences of...more
The Tax Cuts and Jobs Act contains changes impacting the LIHTC Program. While the low-income housing tax credit program emerged largely unscathed, the reduction in corporate tax rates will reduce equity pricing. ...more
On March 29, 2017, Perkins Coie partner Dax Hansen and associate Josh Boehm were invited to the Cyber Initiative at Stanford Law School to deliver a presentation on several cutting-edge legal issues relating to blockchain...more
If you are not a US resident or a US citizen and are considering buying assets in the US, there are ways to avoid or minimize US estate tax on those assets. ...more