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Are Your Lease Payments Still Deductible? The Confounding IRS Guidance Limiting the 'Entertainment' Use of Business Aircraft
In its zeal to eradicate perceived abuses and further clip the wings of executives who, based on press reports, took great pleasure in using the company's airplane for personal purposes, Congress amended section 274(e)(2) of the Internal Revenue Code (the “Code”) in the American Jobs Creation Act of 2004 (“AJCA”). Effective on the date of enactment (Oct. 22, 2004), these amendments effectively reversed the decisions of the Tax Court and Eighth Circuit in Sutherland Lumber-Southwest, Inc. v. Commissioner, 114 T.C. 197 (2000), aff'd 255 F.3d 495 (8th Cir. 2001), acq. AOD 2002-02 (Feb. 11, 2002), and prompted the Internal Revenue Service (“IRS” or the “Service”) to issue guidance containing a myriad of rule changes and hinting at others, leaving tax practitioners scratching their heads and companies running for cover.
On May 27, 2005, the IRS released Notice 2005-45, 2005-24 I.R.B. 1228 (June 13, 2005) (the “Notice”). The rules set forth in Notice 2005-45 create an administrative nightmare for taxpayers and potentially result in the loss of valuable company tax benefits when executives (so-called “specified individuals” and their guests) use the company's airplane for personal purposes. Unfortunately, the Notice, which applies to expenses incurred after June 30, 2005, is difficult to interpret and creates many traps for those attempting to comply with the new deduction disallowance rules.
Sutherland Lumber: Who Says the Good Old Days Weren't Good?
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.