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Administrative Procedure Act Internal Revenue Service Tax Deductions

Downs Rachlin Martin PLLC

Captive Insurance Update | Issue 2 | 2025

Every year, the members of the Vermont Captive Insurance Association’s legislative committee and the Vermont Department of Financial Regulation (the “DFR”) work to improve Vermont’s captive insurance laws and regulations....more

Fox Rothschild LLP

Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current Cases

Fox Rothschild LLP on

On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new language relating to donations of conservation easements by...more

Polsinelli

Big Win for Investors Facing Listed Transaction Penalties for Conservation Easements

Polsinelli on

On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more

Polsinelli

SCOTUS Could Vacate Conservation Easement Regulations

Polsinelli on

As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more

Miller Canfield

Does a Tax Cut Jobs Act Provision Decrease Income Taxes on Marijuana Businesses?

Miller Canfield on

Key Takeaways: ..A pending U.S. Tax Court case presents an interesting theory to preclude the federal income tax disallowance of all deductions of a marijuana business. ..The theory rests on a provision in the 2017 Tax...more

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

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