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In Part One of this article, published last month, we were discussing a hypothetical divorcing couple. The husband would like to keep all of his retirement savings, which have been valued at about 150% of the value of the couple's home, which the wife would like to keep as her own. The husband has offered to exchange his ownership interest in the house for his wife's interest in his retirement savings. His retirement assets consist entirely of pre-tax dollars, and he would like to get a credit for the estimated cost of the unpaid taxes (his combined marginal tax bracket is 33 1/3%). The value of the retirement assets after the tax adjustment would be roughly the same as the value of the house. There are no unrealized capital gains taxes associated with the house.
Taxable Income, Marginal Tax Rates and AMT
There's current litigation in the ongoing Beach Boys litigation saga. A lawsuit filed in 2019 against Nevada residents Mike Love and his wife Jacquelyne in the U.S. District Court for the District of Nevada that alleges inaccurate payment by the Loves under the retainer agreement and seeks $84.5 million in damages.
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
The real property transfer tax does not apply to all leases, and understanding the tax rules of the applicable jurisdiction can allow parties to plan ahead to avoid unnecessary tax liability.