Recent changes allow tax-free receipt of up to $10 million in gain from the sale of small business stock *

USA - January 17 2013
One silver lining to the American Taxpayer Relief Act of 2012 ("ATRA") is that it extended the 100% exclusion for capital gain on qualified small…

Co-authors: David B. Strong, Maureen E. Linch.

A year-end rush for the exit? Tax uncertainty and transactional planning in Q3/Q4 2012 *

USA - August 7 2012
A combination of pending actual and potential tax increases effective in 2013 may have a significant impact on transactional planning in the third and fourth quarters of 2012.

Co-authors: David B. Strong.

2011 Report of Foreign Bank and Financial Accounts ("FBAR") due June 30 *

USA - June 13 2012
We wanted to remind our clients that Treasury Form TD F-90 22.1 “Report of Foreign Bank and Financial Accounts” (commonly known as the “FBAR”) is due on June 30, 2012 with respect to the calendar year 2011.

Co-authors: Thomas A. Humphreys, Edward L. Froelich.

Reasserting its role as final interpreter of the law, the Supreme Court rejects irs "fighting regulation" in United States v. Home Concrete & Supply, LLC, et al. *

USA - May 4 2012
On April 25, 2012, the Supreme Court issued a 5-4 opinion, written by Justice Breyer, concluding that Treasury Regulation § 301.6501(e)-1(a)(iii) was invalid.

Co-authors: Robert A. N. Cudd, Edward L. Froelich, James E. Merritt.