Auditing partnerships has always been procedurally and substantively difficult. As a result, the IRS has audited partnerships….more

Sometimes there is more than one correct way to account for a taxable income (or loss) item. Sometimes one correct way is more advantageous….more

The major Internet company Yahoo!™ (“Yahoo”) inspires the next chapter in our ongoing exploration of just how far a well-connected ….more

As we noted in a recent Alert, sometimes taxpayers take advantage of an unclear law, or even a law that isn’t really all that ….more

As much as national governments like to collect taxes, for the most part they agree that each dollar of income should be ….more

Sometimes the tax law is not as clear as it might be, and taxpayers take advantage of it. Sometimes the tax law is actually fairly clear, but taxpayers ….more

Taxpayers frequently are advised to discard their tax records a few years after filing the tax returns to which they apply. Sometimes taxpayers do so, and then end up wishing ….more

When a business operates in a state, the state typically requires various registrations. When a business operates in several states, each state imposes….more

It actually happens: when a taxpayer that owes a tax cannot pay, another party is made responsible for payment. The risk of such vicarious tax liability is often….more

A leitmotif has arisen in our recent practice, and particularly our mergers and acquisitions practice: questions about when income is received and the corresponding….more

Some business acquisitions involve one payment; others involve several, including deferred or contingent payments. When payments are spread over time….more

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