Abbey Benjamin Garber

Jul 16, 2024 | lexology.com | Jessica Kirk |Lee S. Meyercord |Joshua David Odintz |Abbey Benjamin Garber |Kate Minnich |Mary McNulty

The U.S. Department of the Treasury and IRS on July 11, 2024, issued proposed regulations that would classify certain basket contract transactions as listed transactions. Taxpayers and material advisers participating in listed transactions must comply with disclosure and recordkeeping requirements and are subject to penalties for failure to comply.

May 31, 2024 | jdsupra.com | James Dawson |Abbey Benjamin Garber |Jessica Kirk

The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the taxpayer, the Tax Court rejected the IRS argument that either the common law "conduit" doctrine or the "sham transaction" doctrine should apply to recharacterize the transaction.

May 20, 2024 | jdsupra.com | James Dawson |Abbey Benjamin Garber |Jessica Kirk

The Liberty Global appeal has practitioners and taxpayers concerned that the economic substance doctrine will be applied to disallow the tax benefits of ordinary course of business decisions and disrupt basic tax planning. This trend will be particularly troubling for transactions that are motivated in significant part by tax credits or other tax benefits under the Inflation Reduction Act. The Liberty Global Inc. v.

Mar 21, 2024 | mondaq.com | Abbey Benjamin Garber |Lee S. Meyercord |Kate Minnich

The IRS announced a new campaign to audit high-net-worth taxpayers claiming business deductions for the use of private jets. Using some of the $80 million allocated for enhanced enforcement in the Inflation Reduction Act of 2022 (IRA), the IRS plans to begin "dozens of audits" to determine whether large corporations, large partnerships and high-income taxpayers are properly allocating private aircraft flights between business and personal uses.

Mar 18, 2024 | jdsupra.com | Abbey Benjamin Garber |Lee S. Meyercord |Kate Minnich

March 18, 2024 Abbey Garber, Lee Meyercord, Kate Minnich Holland & Knight LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: The IRS announced a new campaign to audit high-net-worth taxpayers claiming business deductions for the use of private jets.