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The New Pass-through Deduction Explained

USA - January 8 2018 The recently enacted Tax Cuts and Jobs Act introduced a completely new concept to the Internal Revenue Code. IRC Section 199A for the first time...


Assets of Family Limited Partnership Included in Transferor’s Estate

USA - December 16 2016 In Estate of Edward Beyer v. Commissioner, the Tax Court held that substantial assets that Edward Beyer had transferred to a family partnership he...


California State Board of Equalization Rules Against Taxpayer in “Drop and Swap” 1031 Exchange

USA - December 16 2016 It is well known that the State of California does not like "drop and swap" 1031 exchanges. A typical drop and swap scenario involves a partnership...


Final and Temporary Partnership Regulations Make Changes to Disguised Sale and Liability Allocation Rules

USA - December 16 2016 In recent months, the IRS and the Department of the Treasury have issued a number of final, temporary and proposed regulations impacting persons who...


Section 1031 Exchange Runs Afoul of Related Party Prohibition

USA - December 16 2016 In the recent case of Malulani Group, the Tax Court held that the taxpayer's attempt to structure an IRC Section 1031 exchange ran afoul of the...