Articles / Corporate Taxation

View Search Filters
Sham Stock Sales: Acqis Technology v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/18/2024
Download the file for Sham Stock Sales: Acqis Technology v. Commissioner.
Intercompany Loans Recharacterized: 'Fry v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 02/15/2024
Download the file for Intercompany Loans Recharacterized: 'Fry v. Commissioner'.
Transferee Liability under New York Law: 'Dillon Trust Co. v. United States'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 12/21/2023
Download the file for Transferee Liability under New York Law: 'Dillon Trust Co. v. United States'.
Hyatt Hotels: Are Omissions from Gross Income an Accounting Method?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 10/19/2023
Download the file for Hyatt Hotels: Are Omissions from Gross Income an Accounting Method?.
Capital Loss Disputed: Computer Sciences Corp. v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 08/17/2023
Download the file for Capital Loss Disputed: Computer Sciences Corp. v. Commissioner.
When an Expense is Considered 'Paid': 'Gage v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 06/15/23
Download the file for When an Expense is Considered 'Paid': 'Gage v. Commissioner'.
Taxing the Donor upon the Sale of Donated Shares: 'Estate of Hoensheid'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/21/2022
Download the file for Taxing the Donor upon the Sale of Donated Shares: 'Estate of Hoensheid'.
Deductions for Amounts Paid by S Corporation Shareholders Fall between the Cracks
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 02/16/2023
Download the file for Deductions for Amounts Paid by S Corporation Shareholders Fall between the Cracks.
Successor Liability for Taxes: ‘ACI Construction’
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 12/15/22
Download the file for Successor Liability for Taxes: ‘ACI Construction’.
A Trap in the Interest Limit's Small Business Exemption
by Elliot Pisem
Published: Tax Notes, 9/23/2019
Download the file for A Trap in the Interest Limit's Small Business Exemption.
Duty of Consistency Limited: 'Belmont Interests v. Commissioner'
by David E. Kahen
Published: New York Law Journal, 10/20/2022
Download the file for Duty of Consistency Limited: 'Belmont Interests v. Commissioner'.
Deduction Versus Amortization of Start-Up Costs: 'Kellett v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 08/18/22
Download the file for Deduction Versus Amortization of Start-Up Costs: 'Kellett v. Commissioner'.
Challenged Accounting Method Upheld: 'Continuing Life'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 06/16/22
Download the file for Challenged Accounting Method Upheld: 'Continuing Life'.
Federal Tax Guidance Overturned Under Administrative Procedure Act
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/21/2022
Download the file for Federal Tax Guidance Overturned Under Administrative Procedure Act.
Correlative Adjustments Denied: 'FAB Holdings v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 02/17/2021
Download the file for Correlative Adjustments Denied: 'FAB Holdings v. Commissioner'.
Recharacterization of Debt as Equity: 'Tribune Media'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 12/20/21
Download the file for Recharacterization of Debt as Equity: 'Tribune Media'.
'Kelly v. Commissioner': Loans Recharacterized as Distributions
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 10/21/2021
Download the file for 'Kelly v. Commissioner': Loans Recharacterized as Distributions.
Transaction 'Integration': 'GSS Holdings (Liberty) v. United States'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 08/19/2021
Download the file for Transaction 'Integration': 'GSS Holdings (Liberty) v. United States'.
Equitable Estoppel Blocks Taxpayer: 'New Capital Fire v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 06/17/2021
Download the file for Equitable Estoppel Blocks Taxpayer: 'New Capital Fire v. Commissioner'.
'Management Fee' Deductions Disallowed: 'Aspro, Inc. v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/15/2021
Download the file for 'Management Fee' Deductions Disallowed: 'Aspro, Inc. v. Commissioner'.
Taxpayer Prevails on Substance Over Form: 'Complex Media, Inc. v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 02/18/2021
Download the file for Taxpayer Prevails on Substance Over Form: 'Complex Media, Inc. v. Commissioner'.
Tax Treatment of Damages for Accountant Malpractice: McKenny v. United States
by David E. Kahen, Elliot Pisem
Published: December 28, 2020
Download the file for Tax Treatment of Damages for Accountant Malpractice: McKenny v. United States.
'Deckard': Failure to Establish Stock Ownership Defeats S Corp Shareholder Treatment
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 10/16/2020
Download the file for 'Deckard': Failure to Establish Stock Ownership Defeats S Corp Shareholder Treatment.
No “Knowability” Requirement for Theft Losses: Adkins v. United States
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 24, 2020
Download the file for No “Knowability” Requirement for Theft Losses: Adkins v. United States.
No "Knowability" Requirement for Theft Losses: "Adkins vs. United States"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 18, 2020
Download the file for No
Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?
by Ellen Seiler Brody
Published: TaxStringer, May 1, 2020
Download the file for Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?.
Will the Overlap Rule of Code Sec. 1297(d) Still Protect
by Michael J. Miller
Published: International Tax Journal, May - June 2020
Download the file for Will the Overlap Rule of Code Sec. 1297(d) Still Protect .
Income Tax Relief Under COVID-19 Legislation
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 16, 2020
Download the file for Income Tax Relief Under COVID-19 Legislation.
Major Tax Changes in the CARES Act
by Elliot Pisem, Ellen Seiler Brody
Published: R&H Client Letter, April 10, 2010
Download the file for Major Tax Changes in the CARES Act.
Automobiles under the Tax Cuts and Jobs Act of 2017
by Ellen Seiler Brody, Cory M. Paul
Published: Tax Stringer, March 1, 2020
Download the file for <p>Automobiles under the Tax Cuts and Jobs Act of 2017</p> .
Bad Debt Deduction Denied to Guarantor: 'Baker Hughes' v. United States
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2020
Download the file for Bad Debt Deduction Denied to Guarantor: 'Baker Hughes' v. United States.
Transaction Costs (Not) Deductible by Target: "Plano Holding LLC v. Commissioner"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2019
Download the file for Transaction Costs (Not) Deductible by Target:
New Guidance on "Hard Forks" and Changes from LIBOR
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 17, 2019
Download the file for New Guidance on
"Claim of Right" Update: Mihelick v. United States
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 15, 2019
Download the file for
Always Be Nice to Whistle-blowers (And Other Changes Made by the Taxpayer First Act)
by Elliot Pisem, Ellen Seiler Brody
Published: July 25, 2019
Download the file for Always Be Nice to Whistle-blowers (And Other Changes Made by the Taxpayer First Act).
Update on Theft Losses: 'McNely v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 20, 2019
Download the file for Update on Theft Losses: 'McNely v. Commissioner'.
S Corporation Allocations Upon Transfer of Stock
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 18, 2019
Download the file for S Corporation Allocations Upon Transfer of Stock.
Value of Franchise Rights Under BIG Tax: 'H R B-Delaware v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: February 21, 2019
Download the file for Value of Franchise Rights Under BIG Tax: 'H R B-Delaware v. Commissioner'.
Links to the Past: Old Exceptions to New Interest Deduction Limitations
Published: Tax Notes, January 21, 2019
Download the file for Links to the Past: Old Exceptions to New Interest Deduction Limitations.
Qualified Opportunity Zones: Death, Taxes, and Other Uncertainties
by , By Libin Zhang (former partner at Roberts & Holland LLP)
Published: Bloomberg Insights, January 10, 2019
Download the file for Qualified Opportunity Zones: Death, Taxes, and Other Uncertainties.
Adoption and Change of Accounting Method: "Thrasys v. Commissioner"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2018
Download the file for Adoption and Change of Accounting Method:
The Discreet Charms of the Dividends Received Deduction
Published: Tax Notes, November 12, 2018
Download the file for The Discreet Charms of the Dividends Received Deduction.
Qualified Opportunity Zones and Select Partnership Issues
Published: Tax Management Real Estate Journal, November 7, 2018
Download the file for Qualified Opportunity Zones and Select Partnership Issues.
Simultaneous Equations for Simpler Tax Analysis
Published: Tax Notes, October 29, 2018
Download the file for Simultaneous Equations for Simpler Tax Analysis.
S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2018
Download the file for S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'.
Through a Glass Darkly: REIT Earnings and Profits
by Michael S. Grisolia
Published: Tax Notes, October 15, 2018
Download the file for Through a Glass Darkly: REIT Earnings and Profits.
Comments to Proposed Regulations under Section 965
Published: September 18, 2018
Download the file for Comments to Proposed Regulations under Section 965.
Loan v. Distribution: "Illinois Tool Works v. Commissioner"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 16, 2018
Download the file for Loan v. Distribution:
Qualified Opportunity Zones: Hot Tubs and Other Hot Topics
Published: Tax Notes, August 6, 2018
Download the file for Qualified Opportunity Zones: Hot Tubs and Other Hot Topics.
To the Frying Pan: New Virtues of Subpart F over GILTI
Published: Tax Notes, July 2, 2018
Download the file for To the Frying Pan: New Virtues of Subpart F over GILTI.