TAG Tax


Contact: Ilmar-Erik Aavakivi, Aivar Pilv Law Office (Estonia)

On 1 July this year, the changes in the State Fees Act stepped into force which, as the politicians promised, were to reduce the state fees three to five times. As such, the changes are progressive. Yet, they have some “buts”.

Read more: State Fees Reduced Four Times… Really?


Contact: Jenny H. Connors and Allison T. Domson & Conrad Garcia; Williams Mullen (North Carolina and Virginia, USA)

On August 27, 2012, the United States Court of Appeals for the Third Circuit reversed the holding of the United States Tax Court in the case of Historic Boardwalk Hall, LLC v. Commissioner, 136 T.C. 1 (2011). Relying heavily on the decision of the Second Circuit in TIFD III-E, Inc. v. United States, 459 F.3d 220 (2d Cir. 2006) (“Castle Harbour”) and the decision of the Fourth Circuit in Virginia Historic Tax Credit Fund 2001, LP v. Commissioner, No. 10-1333 (4th Cir. 2011) (“Virginia Historic”), the Third Circuit found that Pitney Bowes, Inc. (“Pitney Bowes”), a private sector investor in Historic Boardwalk Hall, LLC (“Historic Boardwalk”), had no meaningful stake in Historic Boardwalk, and, therefore, was not a bona fide partner of the partnership for federal income tax purposes. As a result, all allocations of historic rehabilitation tax credits previously allocated to Pitney Bowes were reallocated to the New Jersey Sports and Exposition Authority (the “New Jersey Sports Authority”) as the owner of East Hall.

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Contact: Boodle Hatfield (London, England)


Friends and property interests

On what basis is a property that has been purchased by friends to be divided?

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The Court of Appeal upholds a son's expectation of inheritance

Where a person has an expectation of receiving certain property from an estate and is left disappointed, they may have a claim based on the doctrine of proprietary estoppel...

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Contact: Spencer Fane Britt & Browne LLP (Missouri, USA)

Business owners are bombarded by the uncertainty caused by the upcoming election and the anticipated 2013 increases in personal income taxes, capital gains

Read more: 2012 Tax Planning Strategies Webinar for Business Owners


Contact: Williams Mullen (North Carolina & Virginia, USA)

This North Carolina corporate income tax alert discusses developments from the recently concluded short session of the General Assembly.

Read more: North Carolina Tax Update