Tax Law News and Insights

Many taxpayers are familiar with information document requests where taxpayers are notified that taxing authorities are inquiring into certain transactions based on their receipt of the request. But today, many types of foreign tax information exchanges occur without the taxpayer's knowledge. Moreover, tax administrations around the world are expanding tax...

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A. Background The Biden administration will propose a change in the tax-free basis step-up at death which has been a part of the tax law for a long period of time. Carter Ledyard's first relationship with this subject occurred in 1970 when Richard B. Covey was contacted by the Trust...

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After Altera's victory in Tax Court in 2015,1 many companies with cost sharing arrangements ("CSA") ceased sharing stock-based compensation ("SBC") costs. To address the possibility of a reversal on appeal, many of these companies added reverse claw-back provisions to their CSAs. Under these provisions, in the year a reversal of Altera becomes final,...

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