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Tax

  • May 24, 2019

    Poland Says Tax Award Shouldn't Pause For Appeal In France

    The Polish government's bid to enforce a $2.6 million arbitration award against American investors who sued over the country’s tax laws should not be paused pending a challenge to the taxes in France, Poland has told a Massachusetts federal court.

  • May 24, 2019

    Ariz. Tax Claim Not Worth Supreme Court Case, Calif. Says

    Arizona's claim that California wrongly taxed Arizona businesses and individuals does not rise to the standard of a matter for original jurisdiction, and the U.S. Supreme Court should decline to hear it, California said in a reply brief Friday.

  • May 24, 2019

    Taxation With Representation: Davis Polk, Sullivan, Sidley

    In this week’s Taxation with Representation, Nuvei buys SafeCharge for $889 million, Dish Network buys broadcast satellite assets from Echostar for $808 million and Aurubis scoops up Metallo Group for $424 million.

  • May 24, 2019

    Trump To Take Bank Subpoena Setback To 2nd Circ.

    President Donald Trump on Friday said he would appeal to the Second Circuit to block congressional subpoenas that seek a vast array of financial records from Deutsche Bank and Capital One, his second such attempt this week to keep his financial records secret.

  • May 24, 2019

    Ala. Construction Co. Owners Cop To Skimming Payroll Taxes

    A married couple that owned and operated a construction business in Alabama have admitted to tax fraud after failing to fork over payroll taxes to the Internal Revenue Service despite skimming the money from employees' pay, the U.S Department of Justice said Friday.

  • May 24, 2019

    DC Circ. Denies $33M Deduction For Land Gift To U Of Mich.

    The D.C. Circuit on Friday said real estate developer Stephen M. Ross and his partners could not deduct $33 million for land donated to the University of Michigan in 2003 and sustained a 40% penalty.

  • May 24, 2019

    UK's Theresa May To Resign As Latest Brexit Plan Founders

    Prime Minister Theresa May announced Friday that she will resign as leader of the Conservative Party on June 7 after facing a backlash from lawmakers over her latest attempt to win support for her much-maligned Brexit withdrawal agreement.

  • May 23, 2019

    Serial ADA-Filing Atty Accused Of Filing False Tax Returns

    A Sacramento-area attorney, known for suing thousands of small businesses under federal and California disabilities laws, has been hit with a federal indictment over allegedly underreporting the taxable income he received from his settlements, the U.S. Department of Justice announced Thursday.

  • May 23, 2019

    Pa. Panel Ducks Ruling On Taxing Homes Based On Sale Price

    A Pennsylvania appeals court has said an Allegheny County judge was right to dismiss a proposed class action lawsuit over whether governments can raise properties' taxable value based on their recent sale prices, but the panel didn't address the parties' central question about whether the practice was legal.

  • May 23, 2019

    China Grants 2-Year Tax Break For Software, Circuit Cos.

    As economic tensions with the U.S. continue to escalate, the China Ministry of Finance has announced a two-year holiday from the country's 25% corporate income tax for local software and integrated circuit companies.

  • May 23, 2019

    PE-Backed Endeavor Group Files $100M IPO Led By 2 Firms

    Private equity-backed entertainment giant Endeavor Group Holdings Inc. filed an initial public offering on Thursday, listing a preliminary funding target of $100 million, under guidance from Latham & Watkins LLP, with Ropes & Gray LLP counseling the underwriters.

  • May 23, 2019

    Senate Panel OKs Covington Partner To Be Tax Court Judge

    The Senate Finance Committee on Thursday unanimously approved the nomination of a Covington & Burling LLP partner to join the U.S. Tax Court as a judge for a 15-year term.

  • May 23, 2019

    Wash. Hikes Biz Taxes To Fund Job Training, Education

    Washington has increased tax rates on certain business services, including work by accountants and lawyers and on certain advanced computing, to raise more than $900 million for job training and higher education, after the governor signed the contested measure.

  • May 23, 2019

    House Approves Bipartisan Retirement Savings Package

    A broad bill to revamp the tax treatment of retirement savings accounts cleared the U.S. House of Representatives Thursday with overwhelming bipartisan support.

  • May 22, 2019

    Dems Warn Of Judicial Overreach As ACA Arguments Loom

    A district court's invalidation of the entire Affordable Care Act was an egregious misuse of judicial power, Democratic lawmakers and state attorneys general told the Fifth Circuit on Wednesday, setting the stage for oral arguments on the ACA's fate.

  • May 22, 2019

    6th Circ. Axes Challenge To Micro-Captive Reporting Rules

    A Sixth Circuit panel affirmed a court order Wednesday dismissing a challenge to Internal Revenue Service guidance that branded some small, in-house insurance companies as tax shelters and required them to be disclosed.

  • May 22, 2019

    7th Circ. Mulls Revival Of Seyfarth RICO Suit

    The Seventh Circuit questioned Wednesday whether an insurance executive had shown a pattern of misconduct and deception of multiple victims that would warrant revival of his racketeering allegations against Seyfarth Shaw LLP and two banks over tax shelter advice.

  • May 22, 2019

    Calif. Senate OKs Special Banks For Pot Biz Tax Payments

    California would create limited charter banks and credit unions that would issue special checks to cannabis businesses for paying state and local taxes, under a bill that the state Senate has approved overwhelmingly. 

  • May 22, 2019

    Venable Adds Tax And Wealth Planning Partner In NY, LA

    Venable LLP has brought on a former Bressler Amery & Ross PC partner as it builds out its tax and wealth planning practice across the country, the firm recently announced.

  • May 22, 2019

    Rhode Island Bridge Tolls Aren't Taxes, 1st Circ. Told

    A law that bars suits that restrain the collection of taxes cannot block a challenge to Rhode Island bridge tolls, since the tolls are not taxes, several transportation groups told the First Circuit in a brief filed Wednesday.

  • May 22, 2019

    Trump Can't Block Dems' Bank Subpoenas, Judge Rules

    A Manhattan federal judge on Wednesday declined to block Deutsche Bank and Capital One from turning over records of President Donald Trump's private real estate business dealings to House Democrats who suspect the Republican president of wrongdoing.

  • May 22, 2019

    Mnuchin, Rettig Didn’t Review Tax Return Disclosure Memo

    Treasury Secretary Steven Mnuchin and IRS Commissioner Chuck Rettig never reviewed an IRS draft memo that said the agency must hand over tax returns requested by Congress unless executive privilege is invoked, Mnuchin told lawmakers Wednesday.

  • May 21, 2019

    NJ Powerbroker Norcross Sues, Claiming Tax Probe Is Illegal

    Southern New Jersey law firm Parker McCay PA and other companies tied to powerful business mogul George E. Norcross III filed a lawsuit Tuesday alleging they were targeted in Gov. Phil Murphy's probe into an $11 billion tax incentive program, despite their roles in revitalizing one of the nation's poorest cities.

  • May 21, 2019

    Tax Evasion Sentence Axed By 10th Circ. As Inappropriate

    The Tenth Circuit on Tuesday affirmed a woman's conviction for tax evasion and bankruptcy fraud for filing a false bankruptcy petition to discharge a $1.2 million tax debt, but vacated her 27-month sentence for improper consideration of her mitigating role.

  • May 21, 2019

    Chancery Denies Legal Fee Recovery For ServiceMesh Buyer

    The Delaware Chancery Court on Tuesday shot down a cloud platform company's bid to make equity holders of an acquired company pay part of an $18 million-and-rising legal bill for its ex-CEO, who was accused of orchestrating a fraudulent, $98 million postmerger earnings bonus in 2014.

Expert Analysis

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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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

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    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
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    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

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    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.