On May 2, 2023, the Department of the Treasury and Internal Revenue Service (“IRS”) issued proposed Treasury Regulations (REG-124064-19) that would, in certain cases, terminate the application of ...

While a claim of conversion has grown to extend beyond tangible property to keep up with computerized use, courts are still grappling with how far to extend the tort. In their Commercial Division ...

The IRS on Tuesday issued proposed regulations that would in certain cases terminate the continued application of Sec. 367(d) when intangible property is repatriated to certain U.S. persons after ...

At the end of the Tax Court’s 2016 opinion in Medtronic, a short section briefly summarizes and summarily rejects what the opinion describes as the IRS’s “alternative allocation under section 367(d).” ...

In In re Estate of Debra E. Hunt v. Arabia Vargas, a trial court granted summary judgment interpreting a will to devise a large share of the testatrix’s personal property to her life partner. No.

Delta Air Lines Inc. failed to convince the US Supreme Court to review Oregon’s policy of taxing the goodwill, intellectual ...

I recently had the opportunity to review all 50 state constitutions and confirmed an important fact for the current capital gains income tax litigation. Although most state constitutions mention how ...

“Starting first with the Napster generation and the view that sharing copyrighted music is somehow an unalienable right in and of itself, the disregard for creators not only transcended the public but ...