Below you will find articles from our legal journals on a variety of pressing legal topics.
Tax counsel often advise taxpayers to apply Internal Revenue Code (Code) section 165(a) to claim an income tax deduction for an uncompensated loss sustained during the tax year. An uncompensated loss occurs when the taxpayer receives insurance...
Insurance. The word itself evokes different reactions. The range of emotions expands when we mention life insurance. And if we add the word trust–life insurance trust–clients may stop listening altogether. But now is exactly the time to be thinking...
With labor shortages currently affecting many industries and with the low national unemployment rate, many private company owners are considering compensation incentives to attract and retain high quality employees. For years, tax counsel have...
If a taxpayer has delinquent tax debts, the taxpayer will generally not receive any tax return refunds due to him.1 The IRS will typically apply whatever refund that taxpayer is owed to a prior year’s tax debt. For example, if a taxpayer has a...
State-by-state statistical analyses suggest that there are presently at least 12 million US LLCs in good standing. It is reasonable to assume that at least 500,000 additional US LLCs will be formed by the end of 2022 and in every year thereafter....
I often have occasion to recount wisdom-laden legal anecdotes for the edification of newer lawyers. These lawyers listen with rapt attention, even while glancing at their phones. Ahead, preserved for posterity, is one of those anecdotes. It...
Tax counsel, and valuation analysts and other financial advisers (analysts), are often retained to advise acquisitive clients with regard to proposed merger and acquisition (M&A) transactions. The analysts typically focus on the pricing and...
So what is an “eggshell audit”? The term refers to the possibility that the subject of a civil audit could, under pressure, crack open and provide information leading to a referral for criminal investigation. The goal of the attorney advising a...
To successfully litigate a case before the U.S. Tax Court, mastery of the applicable substantive tax rules is crucial. However, the importance of the Tax Court’s unique Rules of Practice and Procedure (Rules) should not be overlooked. As one...