California Supreme Court Clarifies Trust Amendment Standards
A California litigator’s framework for navigating exclusivity, delivery, and intent after Haggerty is presented.
Tax Management Memo
Latest Tax Journals
Five Year-End Moves for Small Businesses to Optimize Tax Posture
Small and mid-size businesses and startups should identify and leverage transient opportunities to optimize tax positions for the current year to help set them up for greater financial success in the future.
100% Bonus Depreciation Is Back: Strategies for Implementation
By understanding the limitations, timing rules, and interactions with other tax provisions, taxpayers can strategically incorporate bonus depreciation into their broader tax planning framework.
How Plan Sponsors Can Defend Against Increased 401(k) Litigation
Plan sponsors have some options for protecting themselves from the rise of class action lawsuits.
What to Watch for in the Wake of the Tax Division’s Demise
The plan for restructuring DOJ’s Tax Division may further degrade tax compliance.
Supreme Court Decision Modifies ERISA Litigation Landscape
The alternative safeguards identified in the Supreme Court’s Cunningham v. Cornell decision are discussed for avoiding costly time-intensive discovery for ultimately meritless ERISA claims.
Do Tax Rules Still Favor Charity Over Social Welfare Donations?
OBBBA reduces the income tax benefit of claiming a charitable deduction, prompting donors to reconsider tax implications when deciding between making a nondeductible contribution to a social welfare “lobbying” organization or a deductible contribution to a “charity” organization.
New Notices Make CAMT Regime More Favorable But More Complex
The IRS issued new guidance that would appear to lessen CAMT burdens for many large corporations, but the book-based tax regime remains exceedingly complex.
PLRs Reveal Pointers for Fixing Inadvertent §2632 Elections
Postseason baseball is a metaphor for practitioners seeking relief for a late allocation or election under §2642(g)(1).
SECURE 2.0 Act Reshapes Puerto Rico Retirement Savings Rules
In light of recent Puerto Rico and IRS guidance, some practical considerations on how the SECURE 2.0 Act changes to the Puerto Rico qualified retirement plan rules are analyzed.
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