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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social media platforms in the 2000’...
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Today in Tax: Spin-offs, Tax Elections, and Subpart F
Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation
Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...
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The Magic of Provisional Process
In an economy in which the trial attorney's triumphs are often foiled by an insolvent judgment debtor, prior secured creditors, and bankruptcy, we should all keep in mind the advantages that may be offered to our clients by prejudgment relief in the...
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Heads I Win, Tails You Lose: Should Developers Dissolve Their LLCs After Completing a Project? (Part 2)
The question whether real estate developers should dissolve their limited liability companies ("LLCs") that they typically create for development projects has been a hot topic for the past several years in Washington. As we reported in the November 2...
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