Happy New Year.  Here’s a GLAM on Implicit Support.

“Implicit support” comes charging out of the gates as an early candidate for Word or Phrase of the Year for 2024. 

Before year’s end, the IRS Office of Chief Counsel dropped a new generic legal advice memorandum (“GLAM”), AM 2023-008, titled “Effect of Group Membership on Financial Transactions under Section 482 and Treas. Reg. § 1.482-2(a).” The GLAM visits some familiar territory, including the “realistic alternatives” principle, this time in the intracompany lending context.  

Tax authorities and taxpayers, of course, … Read the rest

New Year, New You? Lessons for the Beleaguered Legal Professional

Here we are, another year.

Do you feel differently? Fresher? Begun again?

2021 was a challenging year for me, and for a lot of people. I lost my dog, who was my heart, after a long and challenging illness that meant we didn’t sleep a lot. My best friend was diagnosed with breast cancer at 36, which means I don’t sleep a lot. There is still a pandemic. I had some chest pains (which, fortunately, turned out to be anxiety … Read the rest