Articles

Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger Tax free spin-off transact...

A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met, stockholders may be able to...

Introduction Part 1 of this series discussed the proposals adopted by various countries to impose taxes on the digital economy, particularly by taxing various types of digital advertising and other digital services. These taxes allow countries to re...

Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...

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’...

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...