Articles

Brief commentary on recent cases, rulings, notices, and related federal tax guidance. Like clockwork, Americans greet each new year with soon-forgotten resolutions and unfounded predictions for the upcoming year. In keeping with that fine tradition,...

For a printable PDF version of this article, please click here. For decades, the United States (U.S.) has boasted the largest economy in the world and the largest market for imported goods. This article discusses basic strategies non-U.S. companies...

Cryptocurrencies, digital assets, and blockchain-based technologies seem to show up everywhere. As the market for these products matures, new markets are emerging. Competitors, new entrants, and investors are acquiring the technologies and platforms...

Brief commentary on the recent developments, cases, rulings, notices, and related federal tax guidance. Biden Administration Budget Proposal May Limit Tax-Free Reorganizations for Corporations with Preferred Stock Recent proposals may limit the abi...

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...

When attempting to exchange a business, exchanging the goodwill component is often a dead end. Goodwill of two different businesses may never be of like kind. Treas Reg § 1.1031(a)-2(c)(2). Goodwill associated with real estate, however, can generally...