The Willens Reportsm

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Foreign Corporations Are Increasingly Engaging In Spin-Off Transactions
October 4, 2024
In the recent past, what had been primarily a domestic corporation phenomenon has begun to be embraced by foreign corporations as well. We are talking about spin-offs. For exam...

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Recent Reports

Each Block Of Stock Transferred Treated Separately
October 4, 2024
In 1975, the taxpayer was the president of X corporation and owned more than 50 percent (by value) of its stock, the remainder of the stock being owned by members of the taxpay...
Jury Will Decide Whether Failure To File FBARs Was Willful
October 4, 2024
In a summary judgment order, the court stated..."Section 5321(a)(5) does not define willfulness, nor has the Ninth Circuit addressed willfulness in the FBAR context."...
Accountant May Have Committed Breach Of Contract And Malpractice
October 4, 2024
V is an online retailer specializing in seed and flower bulbs. In 2017, V engaged JPS to provide various accounting and bookkeeping related services. "Consistent with JPS&...
Section 338 Is The Exclusive Route To Asset Purchase Treatment
October 2, 2024
TowneBank, ("TOWN"), and Village Bank & Trust Financial Corporation, ("VBFC"), recently announced a definitive agreement and plan of reorganization purs...