Implications of Canal Corp. v. Comm'r for U.S. Taxpayers and Their Advisors

Canal Corp. v. Comm'r, 2010 U.S. Tax Ct. LEXIS 25 (T.C. Aug. 5, 2010), has serious implications for U.S. taxpayers and their advisors, especially regarding the issuance of tax opinions requiring a high degree of certainty. Fundamental points of the case as to advisor independence and economic substance...

Georgia Income Tax on Estates & Trusts and Amended Definition of Taxable Nonresident

By Diane L. Mutolo In Georgia, estates & trusts are subject to state income tax. In 2010, the state legislature amended the definition of taxable nonresident to include nonresidents who regularly engaged in certain financially profitable transactions or received deferred compensation or income...

Georgia Income Tax on Estates & Trusts and Amended Definition of Taxable Nonresident

By Diane L. Mutolo In Georgia, estates & trusts are subject to state income tax. In 2010, the state legislature amended the definition of taxable nonresident to include nonresidents who regularly engaged in certain financially profitable transactions or received deferred compensation or income...