Hewitt B. Shaw, Jr.

Hurdle Lowered for LLC/LLP Members to Avoid Passive Activity Loss Rules
William M. Toomajian, Jeffrey H. Paravano, Hewitt B. Shaw, Christopher J. Swift, Edward G. Ptaszek, Paul M. Schmidt, Alexander J. Szilvas, Christina Novotny, August 11, 2009
In two recent cases, the Tax Court and Court of Federal Claims lowered the hurdle for taxpayers who invest in a limited liability company ("LLC") or limited liability partnership ("LLP") to prove they materially participate in the business to avoid the limitation on the use of...

IRS Reverses Position on Like-Kind Exchanges of Certain Intangibles--Opportunities for IP Assets and Business Swaps
Alexander J. Szilvas, Edward G. Ptaszek, Hewitt B. Shaw, William M. Toomajian, Jeffrey H. Paravano, July 13, 2009
The IRS recently reversed its long-standing position that intangibles such as trademarks, trade names, mastheads and customer-based intangibles could not qualify as like-kind property under section 1031 of the Internal Revenue Code (the "Code")