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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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Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
Judge Rules Shaquille O'Neal Will Face Securities Lawsuit for Promotion, Sale of NFTs
A federal district court in Miami, FL, has ruled that former National Basketball Association star Shaquille O'Neal will have to face a lawsuit over his promotion of unregistered securities in the form of cryptocurrency tokens and that he was a "seller" of these unregistered securities.
Why So Many Great Lawyers Stink at Business Development and What Law Firms Are Doing About It
Why is it that those who are best skilled at advocating for others are ill-equipped at advocating for their own skills and what to do about it?
Blockchain Domains: New Developments for Brand Owners
Blockchain domain names offer decentralized alternatives to traditional DNS-based domain names, promising enhanced security, privacy and censorship resistance. However, these benefits come with significant challenges, particularly for brand owners seeking to protect their trademarks in these new digital spaces.
Supreme Court Rules Rejection of Trademark License Does Not Rescind Rights of Licensee
Mission Product Holdings, Inc. v. Tempnology, LLC The question is whether a debtor's rejection of its agreement granting a license "terminates rights of the licensee that would survive the licensor's breach under applicable nonbankruptcy law."