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The timing of a divorce decree can make a big difference in the parties' federal income tax liability because their filing options are determined by their marital status at the end of the tax year. Under federal tax law, taxpayers who were married for 364.5 days but had their divorce decree entered on the afternoon of Dec. 31 are deemed to be single for that tax year. Parties whose divorce decree is entered on the first business day of the new year are married for purposes of filing the previous year's tax returns. Similarly, parties who are divorced or otherwise single during the year who remarry on Dec. 31 are married for purposes of filing their tax returns for that year. Parties who are still married and not judicially separated are married for purposes of filing their tax returns no matter how long they have been separated. IRC ” 6012-6013. It is important to give consideration to the client's filing options because filing status can produce considerable variation in the tax bill on the same income.
Options
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
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.