He threw one or two nice passes but was an immediate defensive liability.
The immediate political liability for this lies with Mr. Brown and the Labour Party, which engaged in a spree of epic proportions after taking power in 1997, spending at a rate that has outstripped inflation by 41 percent.
Cash payouts were preferable, the auditor said, but the financial adviser "strongly resisted the cash payment on the grounds that this will crystallize an immediate tax liability," according to a document provided to The New York Times by Mr. Woodford.
The law firm Weil, Gotschal & Manges told Olympus in a 2008 document, recently provided to The New York Times, that cash payouts were preferable, but that an unnamed financial adviser "strongly resisted the cash payment on the grounds that this will crystallize an immediate tax liability".
Under current law, investors can exchange rental real estate without incurring immediate tax liability, even if they've racked up huge paper gains on their properties.
The I.R.S. treats ordinary L.L.C.s as "pass-through" structures, and shifting financial assets to such entities doesn't usually generate any immediate credits or liabilities.
NSOs are more common and may be awarded to nonemployees, but they bear an immediate income tax liability on any price break upon exercise.
The Court was also only faced with deciding the liability of an immediate tippee, the analyst Dirks.
