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Tax Shelters: New IRS Disclosure Requirements Carry Serious Penalties
Touted as one of the most substantial overhauls of the Internal Revenue Code in years, the American Jobs Creation Act of 2004, Pub. L. No. 108-357, was signed by the President on Oct. 22, 2004. Like any number of omnibus Congressional tax bills, the “Jobs Act” is a broad-reaching collection of miscellaneous tax provisions.
Title VIII of the Act, in Subtitle B ' “Provisions Relating to Tax Shelters,” contains new provisions that limit the benefits of tax shelters. A “tax shelter” includes any plan or arrangement that has as a significant purpose the avoidance or evasion of federal income tax. IRC '6662(d)(2). [Except as noted, IRC references are to the Code as amended by the Jobs Act.]
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Beach Boys Songs Written Decades Ago Triggered Current Quarrel With Lawyers
There's current litigation in the ongoing Beach Boys litigation saga. A lawsuit filed in 2019 against Nevada residents Mike Love and his wife Jacquelyne in the U.S. District Court for the District of Nevada that alleges inaccurate payment by the Loves under the retainer agreement and seeks $84.5 million in damages.
The Article 8 Opt In
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
Major Differences In UK, U.S. Copyright Laws
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
Strategy vs. Tactics: Two Sides of a Difficult Coin
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
Transfer Tax Implications on Real Property Leases
The real property transfer tax does not apply to all leases, and understanding the tax rules of the applicable jurisdiction can allow parties to plan ahead to avoid unnecessary tax liability.