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IRS Provides Transition Relief for Tax-Exempt Leasing: The Internal Revenue Service and the Treasury Department have issued guidance providing limited transition relief for certain partnerships and other pass-through entities that are subject to Section 470 of the Internal Revenue Code, which was added by the American Jobs Creation Act of 2004.
This new provision addresses leases of property in sale-in, lease-out transactions involving tax-exempt entities by suspending the deduction for “tax-exempt use losses” on “tax-exempt use property.” This new provision also applies to certain partnerships. After receiving comments from taxpayers suggesting that certain partnerships may have difficulty applying this provision for 2004, the IRS and the Treasury Department determined that difficulties might exist for 2004 returns with respect to certain property owned by partnerships or other pass-through entities.
Notice 2005-29 announces that the IRS will not apply Section 470 to partnerships or other pass-through entities for taxable years beginning before Jan. 1, 2005, for property that is treated as tax-exempt use property solely as a result of the application of Section 168(h)(6). The notice also requests comments on several issues. Notice 2005-29 will be published in IRB 2005-13.
Yachts, Jets, Horses & Hooch: Specialized Commercial Leasing Models
Defining commercial real estate asset class is essentially a property explaining how it identifies — not necessarily what its original intention was or what others think it ought to be. This article discusses, from a general issue-spot and contextual analysis perspective, how lawyers ought to think about specialized leasing formats and the regulatory backdrops that may inform what the documentation needs to contain for compliance purposes.
Hyperlinked Documents: The Latest e-Discovery Challenge
As courts and discovery experts debate whether hyperlinked content should be treated the same as traditional attachments, legal practitioners are grappling with the technical and legal complexities of collecting, analyzing and reviewing these documents in real-world cases.
Identifying Your Practice's Differentiator
How to Convey Your Merits In a Way That Earns Trust, Clients and Distinctions Just as no two individuals have the exact same face, no two lawyers practice in their respective fields or serve clients in the exact same way. Think of this as a "Unique Value Proposition." Internal consideration about what you uniquely bring to your clients, colleagues, firm and industry can provide untold benefits for your law practice.
Risks and Ad Fraud Protection In Digital Advertising
The ever-evolving digital marketing landscape, coupled with the industry-wide adoption of programmatic advertising, poses a significant threat to the effectiveness and integrity of digital advertising campaigns. This article explores various risks to digital advertising from pixel stuffing and ad stacking to domain spoofing and bots. It will also explore what should be done to ensure ad fraud protection and improve effectiveness.
Turning Business Development Plans Into Reality
This article offers practical insights and best practices to navigate the path from roadmap to rainmaking, ensuring your business development efforts are not just sporadic bursts of activity, but an integrated part of your daily success.