Category Archives: Tax & Estate

New Title! Taxation of Intellectual Property

PLI Press is proud to announce the publication of the new treatise: Taxation of Intellectual Property.

This comprehensive treatise covers the tax consequences of creating, buying, exploiting, and selling various intellectual property assets (including patents, trade secrets, copyrights, trademarks, and computer software), as well as the tax considerations affecting intellectual property litigation.

This book is the essential reference for tax and IP practitioners who want to gain intellectual property taxation knowledge—and strategically counsel their clients on the mounting tax consequences that can affect their bottom line. It differs from other books on taxation of intellectual property in that, chapters dealing with intellectual property creation, acquisitions, and sales and licenses each begin with a general framework for analyzing the tax treatment of all forms of intellectual property. Finally, separate chapters in the book are devoted to the taxation of intellectual property held by corporations and partnership and the taxation of intellectual property held by non-profit organizations.

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 PLI PLUS subscribers can access this title through their subscription.

Treatise Update – The Circular 230 Deskbook: Related Penalties, Reportable Transactions, Working Forms

The Circular 230 Deskbook is an essential compliance resource for every tax professional who practices before the IRS.  It helps practitioners comply with complex Circular 230 amendments more easily — and avoid costly penalties and sanctions.  In addition to demonstrating prescribed duties when advising clients in the preparation of tax returns, it offers quick-reference compliance tools.

This thirty-first release of The Circular 230 Deskbook updates the treatise with the latest developments in tax and estate law relating to IRS Circular 230. Highlights from the new release include:

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update – Mergers, Acquisitions and Tender Offers: Law and Strategies — Corporate, Securities, Taxation, Antitrust, Cross Border

Mergers, Acquisitions and Tender Offers provides battle-tested, real-world advice on the entire M&A process. Packed with best practices, planning tips, checklists, and sample documents/agreements, this treatise offers comprehensive coverage of all aspects of the deal for domestic and cross-border mergers.

Highlights of the new release include:

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update – Langer on Practical International Tax Planning

Langer on Practical International Tax Planning (Fifth Edition) provides current knowledge and expert advice attorneys need to help clients capitalize on ripe tax havens and financial centers. Stocked with case studies that illustrate sound planning approaches, this book delivers the latest word on the legal, tax, business, financial, social, political, technological, geographical, and regional factors to consider when developing and implementing customized planning strategies for clients.

Highlights from the fourth release of the Fifth Edition include:

  • Revised section on Dual Nationality explains that when a taxpayer works in the United States and another jurisdiction, it presents challenges under the Social Security system, including double taxation, incomplete coverage, or loss of continuity of coverage (see section 11:4.1).
  • Revised section on Foreign Bank Account Reporting (FBAR) Rules discusses how a “willful violation” of the FBAR reporting requirement includes both knowing and reckless violations, even though more is required to sustain a criminal conviction for a willful violation of the same requirement; in sum, “willfulness” includes “recklessness” (see section 30:2.3).
  • New section on Sale or Exchange of Partnership Interest explores regulations issued in November 2020, which (1) retain the ten-year exception as an exception to the determination of deemed sale effectively connected gain and loss; and (2) provide rules for the sourcing of deemed sales gain and loss (see section 34:3.2[E]).
  • New section on Foreign Life Insurance Companies examines the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b), for tax years beginning after December 31, 2018 (see section 43:2.1[D]).

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update: Equipment Leasing– Leveraged Leasing

Equipment Leasing−Leveraged Leasing (Sixth Edition) provides readers with the comprehensive legal, tax, economic, accounting, environmental, and insurance information and advice they need to develop and implement leasing deals that maximize rewards and minimize risks.

The authoritative treatise was recently updated with new content to bring readers up to date on the cutting edge of the industry. Highlights from the new release (Release 1) include:

  • Chapter 29: Doing Business Under State Corporation Laws has been fully updated with the latest cases on suits by unqualified foreign corporations, the effect of subsequent qualification, defense of suits, and monetary penalties, as well as cases on doing business in interstate commerce, leasing personal property, and collecting debts.
  • New Appendix 29A provides state-by-state statutory citations on (1) the penalties imposed upon unqualified corporations that are doing business in the state and (2) the activities that may, or may not, constitute transacting intrastate business so as to require qualification.
  • New Appendix 29C includes state-by-state statutes and case law on LLCs doing business outside their state of formation, have also been updated.
  • Chapter 32: Leasing Outside the United States: Pickle, Loss Trapping, Subpart F, and Foreign Tax Credits has been updated with an extensive discussion of new concepts and statutory sections introduced by the Tax Cuts and Jobs Act (TCJA), including: Global Intangible Low Taxed Income (GILTI), Foreign-Derived Intangible Income (FDII), the base erosion and anti-abuse tax (the “BEAT”), the section 163(j) interest expense deduction limitation, and additional provisions impacting leasing transactions.

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update – Circular 230 Deskbook

The Circular 230 Deskbook is an essential compliance resource for every tax professional who practices before the IRS, helping practitioners comply with complex Circular 230 amendments more easily — and avoid costly penalties and sanctions. This treatise was recently updated to include analysis of the latest developments in tax and estate law relating to IRS Circular 230 including the following:

  • Discussion of conflicting 2020 decisions on whether a penalty under section 6707A is void if the IRS notice designating the transaction as a listed one is issued without notice and comment in violation of the Administrative Procedure Act (Michigan) or if that argument can only be pursued in a refund action (Arizona) (See Chapter 1 and Chapter 3).
  • Examination of the difference between the “substantial authority” (having a 40% chance of success on the merits) and “reasonable basis” (where a taxpayer cannot be found negligent if its tax position has a 20% chance of success on the merits) standards under section 6694 (See Chapter 4).

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PLI PLUS subscribers can access this title through their subscription.

New Edition – Art Law: The Guide for Collectors, Investors, Dealers & Artists

PLI Press is proud to announce the publication of the Fifth Edition of Art Law: The Guide for Collectors, Investors, Dealers, & Artists.

From artists to auction houses, from attorneys to appraisal experts, from dealers to collectors — every segment of the art world has found practical guidance and crucial insights in this longtime favorite treatise. Now thoroughly revised, updated, and expanded, the new edition provides more clear, readable coverage than ever before. Key documents, contracts, forms, and checklists make this popular treatise an indispensable resource.

Both authoritative and fascinating in its own right, this new edition analyzes a remarkable range of topics concerning the legal context of the business of visual art, including:

  • The artist-dealer relationship
  • How digital technology and social media affect both commerce in art and the creation of art
  • Tax and estate planning strategies for collectors and artists
  • Artists’ rights under copyright law and the First Amendment
  • New legal challenges for museums
  • Resources for dealing with art theft and artworks confiscated by the Nazis; and more.

PLI PLUS subscribers can access this title through their subscription.

If you would like to purchase a print copy, please email  libraryrelations@pli.edu.

New Edition! Equipment Leasing—Leveraged Leasing

Equipment Leasing—Leveraged Leasing (Sixth Edition) provides readers with the comprehensive legal, tax, economic, accounting, and documentation information and advice needed to develop and implement leasing deals that maximize rewards and minimize risks. Written by more than thirty leading leasing authorities, and featuring hundreds of pages of sample forms, checklists, and documents that expedite successful transactions, this treatise is an essential resource on leasing transactions of all kinds.

The recently published Sixth Edition contains several new chapters including:

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update: Stocker on Drawing Wills and Trusts

Stocker on Drawing Wills and Trusts (Fourteenth Edition) is a vital planning tool for estates, trusts, and tax planning specialists and any general practitioner involved in crafting wills, trusts or other estate planning documents.

For more than 50 years, attorneys and estate planners have relied on this essential treatise to provide high-quality, comprehensive, field-tested drafting guidance that ensures wills, trusts and other estate planning documents fully express clients’ wishes without provoking costly legal challenges.

Enhanced by hundreds of labor-saving sample forms and clauses, this title provides guidance on how to help clients capitalize on the full range of tax-saving and non-tax opportunities.

Highlights of Release #4 include:

  • Chapter 5: Estate Tax and Planning for the Applicable Credit Amount is updated to discuss the inflation adjusted numbers issued by the Service for 2020, and provides updated figures for transfer tax rates, exemption amounts, and the total (federal and state) estate tax top rate.
  • Chapter 6, Section 4.3[F]: Gift Tax on QTIP Property is updated to explain that a major pitfall for QTIP planning is the surviving spouse’s gifting of a QTIP income interest.
  • Chapter 10, Section 10: Income Tax Planning for Other Considerations is expanded to examine changes to the Kiddie Tax for taxable years 2018–2025, during which the child’s unearned income will be taxed at the ordinary and capital gains rates applicable to trusts and estates.

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PLI PLUS subscribers can access this title through their subscription.

Treatise Update: International Tax & Estate Planning

International Tax & Estate Planning: A Practical Guide for Multinational Investors (Third Edition) presents the clear and practical approach of a person who deals with private wealth, its management and its disposition. In it, one of the nation’s leading multinational investment authorities shows you how to: capitalize on tax-advantaged strategies, protect investments against government expropriation, nationalization, or other extraordinary events, draft problem-free wills and trust documents that secure clients’ interests, and avoid errors in an era of increased regulatory oversight, conflicts of law, and greater demands for financial disclosure.

This title is an indispensable resource for lawyers, private bankers (both investment and commercial), corporate personnel of multinational corporations, accountants, and investment advisers.

This latest release updates the text with the practical information that enables multinational investors (and those who advise them) to protect investments, minimize taxation, maintain confidentiality, and assure proper disposition of assets upon an investor’s death.

A completely revised Chapter 5: Sovereign Risks, Expropriation, and the Act of State Doctrine, explores topics including: what constitutes just compensation; the Foreign Account Tax Compliance Act and Common Reporting Standard; sanctions imposed by the United States on Iran, Russia, North Korea, Venezuela, and Cuba; and questions that can be used to determine whether a constructive taking has occurred.

This essential treatise is available on PLI PLUS. If you would like to order a print copy, please contact libraryrelations@pli.edu.