As we have previously written, a new package of “tangible property” regulations is scheduled to take effect at the beginning of 2014. The regulations include complex and specific definitions of …more

After a respectable number of false starts, comment periods and issuances of interim guidance, the Treasury Department has issued final “tangible property” regulations. The regulations are intended to…more

It sounds too good to be true, and soon it may be. The full income exclusion for gains on the sale of qualified small business stock is set to expire at the end of 2013. While that benefit has been renewed before, this seems likely to…more

Tax avoidance through holding assets offshore has been a prominent theme in the news lately. Sometimes it looks worse than it is; sometimes it is worse than it looks. This ALERT discusses the basic tax issues…more

When a corporation purchases an 80% controlling interest in the stock of another corporation, the parties generally can make an election to treat the
transaction as an asset purchase. In 1986 Congress enacted…more

When a purchaser purchases an item of tangible personal property from a seller in another state, the sale is not subject to sales tax. Instead, the buyer is required to…more

We have recently had discussions with a few clients who discovered tax deductions or credits they could have claimed in past years. In some cases…more

In the recent Tax Court case of a partnership called 6611, Ltd., the taxpayer lost for an embarrassing reason. The taxpayer had carried out a transaction intended to create …more

The legislative deal to resolve the “fiscal cliff” primarily concerned deficit and stimulus measures. However, it resulted in some favorable tax law changes. This Alert describes those changes that are most likely to be…more

The Court of Appeals for the Ninth Circuit recently affirmed the Tax Court victory of a taxpayer called Flextronics. In doing so, it rejected some highly aggressive government arguments. It also reminded us of…more

Subscribe to our Future
Monthly Tax Alerts
Your Name:  
Your Email:  

Your information will not be shared with any third party.