Let's Talk About the Anatomy of a Prenuptial Agreement
Advancing Agriculture: Security Interests and Article 9 Challenges (Part 2)
The application cycle for the first round of credits will soon open. Treasury’s additional guidance clarifies what types of facilities may qualify for credits, the submission process and the selection criteria for evaluating...more
In Notice 2014-21, the IRS announced its position that cryptocurrencies constitute property for tax purposes, rather than foreign currency, and observed that while cryptocurrency may operate like “real” currency in some...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
On June 11, the IRS released Proposed Treasury Regulations (the Proposed Regulations) under Section 1031 of the Internal Revenue Code, as amended (the Code), which provide a much-awaited definition of “real property” and...more
Seyfarth Synopsis: On June 12, 2020, the US Department of Treasury (the “Treasury”) promulgated proposed treasury regulations (the “Proposed Regulations”) under section 1031 (“Section 1031”) of the Internal Revenue Code of...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 legislation commonly referred to as the Tax Cuts and Jobs Act (the "Act") that was signed into law in late 2017, ushered in significant changes to the Internal Revenue Code (the "Code"). Some of these changes are...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
BACKGROUND - On February 21, 2014, then House Ways and Means Committee Chairman Dave Camp (R-Michigan) issued a discussion draft of the “Tax Reform Act of 2014.” The proposed legislation spanned almost 1,000 pages and...more