Tax Law News and Insights

I. Introduction When a U.S.-based cash-basis law firm receives a contingency fee, the fee generally is subject to U.S. federal income taxation in the year the settlement occurs and the fee is paid out by the defendant or its insurer (Settlement Year). Some law firms have arranged for a third...

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On December 22, 2022, the Internal Revenue Service (IRS) finalized changes to Schedule UTP, Uncertain Tax Position Statement, and Instructions for Schedule UTP. Proposed changes to Schedule UTP and the UTP Instructions were announced on October 11, 2022, with comments requested by November 18, 2022. Our prior coverage of the proposed changes...

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Q: What is Upstream Gifting and How Can it Minimize My Taxes? A: The average American is generally unconcerned with federal estate taxes because exclusions are historically high (in 2023, an individual can exclude a whopping $12.92MM from his or her estate before any estate taxes are due; $25.84MM for a...

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