When toddlers engage in parallel play, the children play adjacent to each other, but do not try to influence one another’s behavior. Apparently, parallel play can extend well into adulthood and to the writing of federal...more
6/23/2025
/ Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Pass-Through Entities ,
Private Funds ,
Proposed Legislation ,
SALT ,
Senate Finance Committee ,
Tax Deductions ,
Tax Legislation ,
Tax Reform
In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more
On May 9, 2025, the House Ways & Means Committee released its initial draft of President Trump’s “big, beautiful bill.” The bill will set the stage for extending the tax cuts enacted in 2017 as part of President Trump’s first...more
5/14/2025
/ Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Individual Retirement Account (IRA) ,
Proposed Legislation ,
SALT ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
In Advice Memorandum 2010-005, the Internal Revenue Service (IRS) set out its position that “basket options” conveyed so many attributes of ownership over the securities referenced in these options to the optionee that the...more
4/23/2025
/ Basket Transactions ,
Capital Gains ,
Disregarded Entities ,
Financial Markets ,
Hedge Funds ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Securities Transactions ,
Tax Court ,
Tax Liability ,
Tax Planning