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Could solicitor-client privilege be a hallmark of a reportable transaction under proposed S. 273.3 of the Income Tax Act?
  • Dentons
  • Canada
  • November 28 2012

Under proposed 237.3 of the Income Tax Act, a “reportable transaction” is an avoidance transaction that has two of three “hallmarks” (fee hallmark, confidential protection hallmark, or contractual protection hallmark

Estate tax, income tax and other federal benefits now available to same-sex married couples
  • Dentons
  • USA
  • October 24 2013

In June 2012, the United States Supreme Court rendered two historic decisions. In Hollingsworth v. Perry, the Supreme Court made same-sex marriage in

  • Pepper Hamilton LLP
  • USA
  • September 21 2012

"Portability" allows a surviving spouse to use the unused federal estate tax exemption of the first spouse to die in cases where the first to die had insufficient assets at death to fully use his or her own exemption

Marriage and tax breaks in the news
  • Morton Fraser
  • United Kingdom
  • January 6 2012

Recent BBC coverage of Government debates on the institution of marriage caught our attention

Searching for guidance regarding making a portability election?
  • Bryan Cave LLP
  • USA
  • March 23 2012

In Notice 2011-82, 2011-42 IRB 516, 09262011 the Service reiterated much of the instructions on portability addressed informally in the Instructions for Form 706 for 2011 decedents

2011 fall estate planning
  • Baker Donelson Bearman Caldwell & Berkowitz PC
  • USA
  • November 17 2011

The federal estate and gift tax exemption is $5,000,000 in 2011, and is currently anticipated to be $5,120,000 through the end of 2012

Limits on a professional’s liability to third parties
  • Borden Ladner Gervais LLP
  • United Kingdom
  • October 17 2012

Useful stuff in Arrowhead Capital Finance Ltd v KPMG LLP, 2012 EWHC 1801 (Comm

Rare victory for corporate taxpayers provides insight to in-house tax departments regarding employee privacy and privileged documents
  • Mayer Brown LLP
  • USA
  • October 10 2012

On August 15, 2012, the United States District Court for the Northern District of Ohio ruled for the taxpayer in three out of four Internal Revenue Service (“IRS”) summons enforcement actions

Laws and orders brought into force in 2012
  • Bedell Cristin
  • Jersey
  • September 7 2012

The Banking Business (General Provisions) (Amendment No. 3) (Jersey) Order 2011 came into force on 25 January 2012. The Order amends the Banking Business (General Provisions) (Jersey) Order 2002 in relation to deposit taking

Statute of Elizabeth v Trusts: the increasing use of the fraudulent conveyances act to undo tax and estate planning
  • DLA Piper LLP
  • Canada
  • November 16 2012

Two recent appellate decisions out of Alberta and BC demonstrate the willingness of courts to privilege the interests of spouses over the ability to enforce properly constituted trusts and legitimate estate planning