law Archive

IRS Announces It Will Start Following the Law (With Respect to Identifying Some Listed Transactions)

TweetShareSharePin0 Shares Today’s guest post is from Jonathan Black, a senior associate in the Washington DC office of Caplin & Drysdale. Jon discusses the IRS’s latest efforts to address conservation easements, a topic that has generated considerable litigation and discussion on the blog. As Jon notes, the implications of the IRS’s actions this week may

U.S. Congressman “Defied Property Tax Law” For Nearly a Decade

TweetShareSharePin0 Shares U.S. Congressman Vicente Gonzalez of Texas has “defied property tax law” for nearly a decade by claiming two homestead exemptions. 54-year-old Democrat Gonzalez represents Texas’s 15th District in the United States House of Representatives. He was first elected in 2017.  Now, it has come to light that the politician and his wife claimed two

Contract Law and Rejecting Offers in Compromise

TweetShareSharePin0 Shares I apparently cannot stop writing about Offers and “deemed acceptance” under IRC § 7122(f). This is because I think it represents fertile ground for practitioners to help their clients, a way to hold the IRS accountable for getting things done in some semblance of a timely manner, and fix (or invalidate) an indefensible

Spain Start-Up Law Tax Proposal: Details & Analysis

TweetShareSharePin0 Shares Three years after its initial announcement, Spain’s government has given a green light to the “start-up law” and sent it to parliament. The bill that could be approved by mid-2022 is part of the reform package that Spain and the European Commission agreed upon in order for Spain to receive the European Union

Pandora Papers: law firms must disclose clients’ names (like they’ve started doing in the US of all places)

TweetShareSharePin0 Shares This blog post contextualises the new Pandora Papers leak. It explains the need for public beneficial ownership registries, it opposes the latest opinion by the EU Data Protection Supervisor on the matter, and it shows how to use recent US case law to get the names of enabler’s clients, regardless of professional secrecy.

The Law Does Not Forbid a Helpful Internal Revenue Policy

TweetShareSharePin0 Shares Commenter in chief Bob Kamman returns with a colorful story following up on yesterday’s topic of jeopardy assessment. The Fumo case, of course, is small potatoes.  If you want a real jeopardy assessment involving a real politician, you have to go back to March 13, 1925, when Internal Revenue assessed James Couzens, United

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