Tax

Real-Life Lessons For Lawyers From 'Game Of Thrones'

What lessons can the various hands, maesters, council members and other advisers in "Game of Thrones" impart to real-life lawyers? Quite a few, if we assume that the Model Rules of Professional Conduct were adopted by the Seven Kingdoms, says Edward Reich of Dentons.

5 Tips To Help Your Summer Associates Succeed

There are a number of ways that attorneys can ensure their summer associates successfully manage critical writing assignments and new types of professional interactions, says Julie Schrager of Schiff Hardin.

Unpacking Treasury's New Opportunity Zone Rules

The U.S. Department of the Treasury and Internal Revenue Service recently issued a second round of proposed regulations providing guidance for qualified opportunity fund investors and sponsors. Kelsey Lemaster and Karen Turk of Goodwin discuss the significant points that were addressed and the clarifications that are still needed.

Challenges To Trump's '2 For 1' Order Face Difficult Road

Shortly after President Donald Trump took office, he issued an executive order directing agencies to eliminate two existing regulations for every new regulation adopted. Multiple lawsuits challenging this order are ongoing, but federal courts are poorly equipped to adjudicate claims that involve an agency’s failure to regulate, says Steven Gordon of Holland & Knight.

Keys To Communicating A Law Firm's Mission

Today’s law firm leaders are pretty good at developing a strategic vision for the enterprise, but there is often a disconnect between that road map and the marketing department’s rank and file, leading to a deliverable that does little to differentiate the firm, says José Cunningham, a legal industry consultant.

Decedent Transition Tax Liability Puts Estates In Tough Spot

Despite requests to the contrary, recent regulations by the U.S. Department of the Treasury define a taxpayer's death as an acceleration event for the purposes of Section 965 transition tax deferral thereby additionally burdening the decedent’s estate, beneficiaries and transferees, says Carlos Somoza of Kaufman Rossin.

Why Controversy Surrounds Extension Of IRS Pilot Program

The IRS Office of Appeals recently announced a one-year extension of its appeals process pilot program — unwelcome news to many taxpayers who say the program undermines the office's independence, say Jason Dimopoulos and Tom Linguanti at Morgan Lewis.

High Court Hyatt Decision Fortifies Tribal Sovereignty

The U.S. Supreme Court's reflections on state sovereign immunity in Franchise Tax Board of California v. Hyatt bode well for tribes, because the court's emphasis on the founders' vision of sovereign immunity should extend to tribal sovereignty as well, says Jennifer Weddle of Greenberg Traurig.

Opinion

How Lawyers Can Help Save The Planet

Over a dozen major law firms have joined our effort to overcome the legal obstacles that states, cities and businesses face in fighting climate change. But more lawyers are needed, say Michael Gerrard of Columbia Law School and John Dernbach of Widener University Commonwealth Law School.

Wealthy Individuals In Crosshairs Of Chinese Tax Enforcement

The anti-avoidance provisions of the recently amended Chinese individual income tax law, in conjunction with changes to the common reporting standard, show that China intends to strengthen tax enforcement on high net worth individuals, say Amy Ling of Baker McKenzie and Jason Wen of FenXun Partners.

Taxpayers Should Prepare For The Next Penalty Battleground

Recent informal IRS guidance, audit activity and pending litigation indicate that Internal Revenue Code Section 6676, a rarely used penalty provision, may soon become the IRS’ favorite new compliance tool, say attorneys at McDermott.

Partnership Buyers, Beware IRS Withholding Proposal

New proposed treasury regulations, which would implement the Tax Cuts and Jobs Act's income tax withholding regime for transfers of foreign partnership interests, make several significant changes to earlier IRS guidance, say attorneys at Dentons.

Opinion

IRS Should Use Tax Law To Combat The Opioid Epidemic

The IRS, which enforces anti-trafficking tax laws against state-regulated cannabis businesses, should be fair and apply the same policy against pharmaceutical companies that illegally market their opioids, says Kat Allen at Wykowski Law.

Treasury's New Rules Streamline Opportunity Zone Program

Excerpt from Lexis Practice Advisor

The U.S. Department of the Treasury's second set of proposed regulations on the opportunity zone program make participation easier overall and open the door for operating businesses in OZs, though not all the new provisions are welcome, says Jessica Millett of Duval & Stachenfeld.

The Evolution Of Software As A Service Taxes Post-Wayfair

Due to the expanded nexus provisions following South Dakota v. Wayfair, software as a service providers need to be especially aware of the recent — and, at times, divergent — state law developments in SaaS taxation, say attorneys at Pillsbury.