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Two recently published tax-related law review articles were either written by or feature Gunster attorney Alan S. Lederman.

Lederman is a nationally renowned author, and his law review articles have been cited frequently by both government agencies and private practitioners. He has considerable experience in most aspects of income tax planning and income tax controversies, including those related to international transactions. He is Florida Bar board-certified in tax law, and his clients range from major multinational corporations to local businesses.

Related-party exchanges

The April 20 Bloomberg BNA Insights article Lederman co-wrote concerns a common situation where an equipment franchisee owns both a leasing company and a dealership. The dealership buys some of its equipment from the manufacturer (here Caterpillar) with a view to replacing the leasing company’s rental equipment when the lease on that equipment runs out and the leasing company sells the used rental equipment on the open market at a profit.

The article criticizes the federal courts’ controversial decision in North Central Rental & Leasing v. United States to deny the leasing company the tax-free rollover to which that leasing company would unquestionably have been entitled had it hypothetically bought the replacement equipment directly from the manufacturer rather than from its related dealer, even if the dealer, at the time it bought the equipment from the manufacturer, planned to and did resell that equipment to the leasing company as replacement rental equipment.

Find out more in the April 20, 2015, Bloomberg BNA Insights, Daily Tax Report article: Section 1031 Exchanges: Death of a Related-Party Exchange – Did ‘Butler’ Do It? by Bradley T. Borden and Alan S. Lederman (subscription req’d).

BNA Insights articles feature unique perspectives from expert tax professionals and thought leaders on judicial, regulatory, and legal developments.

Foreign procurement tax exclusions

This article by Tax Analysts – Tax Notes Today discusses the Treasury’s proposed foreign procurement payment regulations issued April 20, and the IRS’ related notice issued the following day.

Lederman is one of two attorneys quoted in the article discussing which of the proposed regulations’ provisions are helpful – such as allowing free trade agreement countries to qualify for an exemption to the tax – and which are not – such as the lack of an exception for U.S.-owned foreign contractors.

Find out more in the April 21, 2015 Tax Analysts article: Foreign Procurement Payment Proposed Regs Have Treaty Exclusion (Section 5000C – Foreign Procurement Tax) (subscription req’d).

 

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