Case Summaries Nosirrah Management, LLC v. AutoZone, Inc., (W.D. Tenn. April 14, 2025)

A recent court order ameliorates concerns from a prior order suggesting that swap powers should not be used in GRATs for insider stock. The final order dismissing the case provides that the “mere change of form and no change in pecuniary interest” exemption for Section 16(b) applies to the distribution of insider stock in satisfaction of GRAT annuity payments.