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Shareholders Tax Assessment

Morgan Lewis

No Gift Tax on Increases in the Value of Shares in the Case of Shareholder-Allocated Contributions

Morgan Lewis on

In a proceeding for suspension of enforcement, the Federal Fiscal Court (BFH) has concluded that also disproportionate contributions into the capital reserve do not constitute a gift tax-relevant increase in the value of...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

Foster Garvey PC on

Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

Barnea Jaffa Lande & Co.

New Israeli Court Ruling on Artificial Transactions

A recent court ruling in the Shalam Packaging Products Group case addressed claims made by the Netanya tax assessor. The assessor argued the group executed a restructuring solely to reduce its tax liabilities by offsetting...more

Fenwick & West LLP

Recent Tax Court Decision in Crestek – a Cautionary Tale for U.S. Companies with Foreign Subsidiaries

Fenwick & West LLP on

In a ruling with tax implications for U.S. corporations with foreign subsidiaries, the U.S. Tax Court has held that transactions between a U.S. parent company and its controlled foreign corporations constitute “United States...more

Proskauer Rose LLP

Wealth Management Update - June 2013

Proskauer Rose LLP on

The June § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2%, which is a slight decrease from April's rate of 1.4% but remains the same as May's rate of 1.2%. The applicable federal...more

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