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Results:1-10 of 25

The Tall Tax Tale of Why Country Songwriters Get Capital Gain Treatment
  • Sullivan & Worcester LLP
  • USA
  • August 18 2017

As a tax lawyer, my professional life has the elements that my grandfather believed were essential to a really good job: indoor work, no heavy


American Taxpayer Relief Act of 2012 extends bonus depreciation for aircraft
  • Sullivan & Worcester LLP
  • USA
  • January 7 2013

As part of the American Taxpayer Relief Act of 2012 -- the legislation that was the product of the "fiscal cliff" negotiations in Washington -- Congress


Change in IRS position creates additional tax exposure for aircraft management companies and aircraft owners
  • Sullivan & Worcester LLP
  • USA
  • December 18 2012

Earlier this year, the Internal Revenue Service issued a Chief Counsel Advice (CCA 2012-10026) that addresses the taxability of aircraft management fees as amounts “paid for the taxable transportation of persons” that are subject to the 7.5 Federal Transportation Excise Tax imposed by 4261 of the Internal Revenue Code (the “FET”).


This year’s trap for the unwary: year-end deadline to amend release provisions
  • Sullivan & Worcester LLP
  • USA
  • November 6 2012

Employment, severance and change in control agreements often contain provisions requiring a service provider (employee) to provide a release of claims against the service recipient (employer) in order to receive a payment.


Month-end benefits reminders and 2011 changes
  • Sullivan & Worcester LLP
  • USA
  • January 19 2011

Corporations issuing incentive stock options ("ISOs") and shares under employee stock purchase plans ("ESPPs") have historically been required to provide certain information to optionees each year.


Capital gain exclusion rate increased to 100 for qualifying investments
  • Sullivan & Worcester LLP
  • USA
  • October 26 2010

One under-publicized tax planning opportunity contained in the Small Business Jobs Act of 2010 (the "2010 Act"), signed into law on September 27, is a provision permitting non-corporate taxpayers to lock in during 2010 a zero percent federal income tax rate on gain (subject to certain limitations) realized on a later sale of certain "qualified small business stock" ("QSBS").


Bonus depreciation extended for 2010
  • Sullivan & Worcester LLP
  • USA
  • October 12 2010

On September 27, 2010, President Obama signed into law the "Small Business Jobs Act of 2010."


Internal Revenue Service ignores trust amendment designed to create designated beneficiary
  • Sullivan & Worcester LLP
  • USA
  • August 1 2010

Private Letter Ruling 201021038 (May 28, 2010) shows the importance of careful drafting for a trust designated as the beneficiary of a retirement plan.


Xilinx: time for a tweak to Treas. Reg. Section 1.482-1(b)(1)?
  • Sullivan & Worcester LLP
  • USA
  • July 12 2010

The Xilinx case has been quite a ride.


Tax law update
  • Sullivan & Worcester LLP
  • USA
  • June 1 2010

On March 24, the House passed H.R. 4849, the Small Business and Infrastructure Jobs Tax Act of 2010, which includes an amendment to Internal Revenue Code Section 2702 imposing a minimum term of 10 years for grantor retained annuity trusts (GRATs).