EVENT CALENDAR

Happy holidays from the Fifth Circuit! Corporate Transparency Act (CTA) filings are back on (for now). On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the district court’s preliminary injunction enjoining CTA entered in the case of Texas Top Cop Shop, Inc. v. Garland. So, until the Department of the Treasury’s ongoing appeal of the district court’s order is finally resolved, the requirement to file is back on.

The Step-Transaction Doctrine is often employed by the IRS to challenge clients’ planning. There is limited time in2024, and soon the compressed planning period of 2025. There are steps that practitioners might recommend to their clients to take now in preparation for future planning, which could potentially mitigate the possibility of the IRS successfully raising the step-transaction doctrine on audit. There is no universally accepted test to determine if the step-transaction doctrine should be applied to a particular transaction.  However, Courts have relied on three concepts when evaluating whether the step-transaction doctrine should be applied: the mutual interdependence test, the end result test, and the binding commitment test.

The 59th Annual Heckerling Institute on Estate Planning was held in Orlando, Florida, on January 13-17, 2025. The Institute is the preeminent estate planning conference of the year and always provides a full week of valuable seminars covering a broad range of estate planning issues for all types of practitioners and all types of clients. Not only does the Institute inform planners of new developments from the past year and state of the art estate planning techniques, but it also includes an array of eclectic topics to broaden the knowledge and perspective of practitioners attending.