The recently passed federal tax cut bill slashed income tax rates for corporations, but in the absence of guidance from the Internal Revenue Service, some pass-through businesses are holding off on restructuring that might take advantage of the reduced rates.
Law360 Tax TAX

Saturday, February 24, 2018 Follow Tax Law360

TOP NEWS

Analysis

Pass-Throughs Await IRS Guidance Before Restructuring

The recently passed federal tax cut bill slashed income tax rates for corporations, but in the absence of guidance from the Internal Revenue Service, some pass-through businesses are holding off on restructuring that might take advantage of the reduced rates. Read more »

Trump's Ex-Campaign Officials Face New Tax, Fraud Charges

Special Counsel Robert Mueller on Thursday unsealed a slew of new tax- and bank fraud-related criminal charges against President Donald Trump's former campaign officials Paul Manafort and Richard Gates, alleging they filed false income tax returns and failed to report foreign bank accounts. Read more »

Feds Ask DC Circ. To Reinstate Tax Preparer ID Fees

Seeking to overturn a federal court decision, the IRS told the D.C. Circuit on Wednesday it had the authority to charge $37.6 million in fees to issue and renew preparer tax identification numbers because a PTIN has value — it protects a tax preparer’s Social Security number and helps the preparer avoid a penalty of up to $25,000. Read more »

Analysis

Tax Specialists Call For Generous Reading Of BEAT Provision

A literal reading of one of the new international provisions in the recent federal tax overhaul could have the unintended consequence of encouraging U.S. companies to change their operations to avoid the harsh treatment, practitioners said. Read more »

Treasury Official Keeps Mum On BEAT Anti-Abuse Rules

Taxpayers can expect guidance dealing with how the new U.S. tax law’s base erosion and anti-abuse measure will affect partnerships, a U.S. Department of Treasury official said Thursday at a conference in Houston, although he kept mum on how the government would interpret its related authority to curb avoidance. Read more »

Tax Law Could Keep IP From Leaving, Treasury Official Says

An international provision in the new tax law might not result in U.S. companies bringing intellectual property back home, but the measure could keep them from moving more assets outside of American borders, a U.S. Treasury official said Thursday at a conference in Houston. Read more »

FEDERAL

Chamber Seeks Clarity For Tax Law's Repatriation Rules

The U.S. Chamber of Commerce has asked Treasury and IRS officials to clarify the terms of recent guidance that give multinational corporations some wiggle room in determining the amount of offshore income eligible for a one-time discounted tax rate under the newly enacted tax cut law. Read more »

STATE & LOCAL

Wash. House To Vote On Budget With Capital Gains Tax

Washington state Democrats are moving ahead with a proposal for a capital gains tax, a controversial plan that critics have decried as a back-door attempt at taxing income in the state. Read more »

NY Tells 2nd Circ. To Toss Couple's $5M Income Tax Appeal

The New York State Department of Taxation and Finance and other state agencies told the Second Circuit on Wednesday to reject a couple's suit alleging the agencies violated their constitutional right to live in separate states by requiring the couple to pay New York taxes on $5 million in capital gains from selling property in Florida. Read more »

INTERNATIONAL

BBC, Guardian Say Public Duty Trumps Appleby Records Suit

The BBC and the Guardian have told a British court that they're not liable for any damages their reporting caused offshore law firm Appleby Global Group LLC, arguing that while they knew portions of the Paradise Papers likely contained privileged communications, publishing portions of the leaked documents crucially furthered the public debate.  Read more »

EXPERT ANALYSIS

Breaking Down The New Interest Deduction Limitation Law360 Video

Breaking Down The New Interest Deduction Limitation The Internal Revenue Code has historically limited the ability of corporations to deduct certain interest paid to related parties, but the recent tax reform modified this limitation and expanded its application. In this video, Taylor Kiessig and Brian Tschosik of Eversheds Sutherland LLP discuss differences between the historic and new versions of this limitation on interest expense. Read more »

LEGAL INDUSTRY

Feature

How Mentors For Senior Partners Could Benefit BigLaw

Large law firms have long offered mentorship programs in which senior partners bestow pearls of wisdom upon junior attorneys, but at least one law firm is shaking up that traditional model in what some say could be a game-changer for the legal industry. Read more »

Analysis

Ex-Skadden Atty's Plea Raises Specter Of Foreign Lobbying

The sudden guilty plea of a now-former Skadden lawyer who helped write a legal analysis commissioned by Paul Manafort on behalf of a Ukrainian president puts further scrutiny on the firm’s role in the controversial report and whether Skadden crossed into the legally precarious position of unregistered lobbying for a foreign government, experts said. Read more »

LSAT Administrator Likely In Contempt As Feds Sit Idly By

A California federal judge said Friday that the Law School Admission Council Inc. was likely in contempt of a consent decree laying out ways it should accommodate disabled test takers, adding it was “astounding” that the federal government took no position on the alleged violations after it had vigorously pursued the litigation for several years. Read more »

Up Next At The High Court: Antitrust Rule, Public Unions

The U.S. Supreme Court is closing out its February oral argument session with a blockbuster docket, taking on a key doctrine of antitrust law in a case involving American Express Co. and pondering the fate of public sector unions. Read more »

GC Cheat Sheet: The Hottest Corporate News Of The Week

A report revealed that National Public Radio management hired and retained news executive Michael Oreskes despite multiple "flags" regarding his inappropriate behavior toward women, Democrats dinged new U.S. Securities and Exchange Commission guidance as old advice, and the general counsel of Discover Financial Services spoke with Law360 about how the company prioritizes diversity and inclusion. These are some of the stories in corporate legal news you may have missed in the past week.​ Read more »

Podcast

Law360's Pro Say: Microsoft's Supreme Court Privacy Battle

On the latest episode of Law360's Pro Say podcast, we are joined by Microsoft's head of litigation to talk about upcoming U.S. Supreme Court oral arguments in a privacy case over data stored on servers overseas. We also chat about a BigLaw attorney swept up in Robert Mueller's ongoing investigation, the Supreme Court narrowing legal protections for corporate whistleblowers, and a legal beef over Dunkin' Donuts Angus steak sandwiches. Read more »

In Case You Missed It: Hottest Firms And Stories On Law360

For those who missed out, here's a look back at the law firms, stories and expert analyses that generated the most buzz on Law360 last week. Read more »

JOBS
Search full listings or advertise your job opening
Law360 Pro Say Podcast

Listen to our new podcast here

LAW FIRMS

Allen & Overy

Alston & Bird

Appleby Global

Arent Fox

Boies Schiller

Bond Schoeneck

Caplin & Drysdale

Covington & Burling

Cravath Swaine

DLA Piper

Doar Rieck

Eversheds Sutherland

Fenwick & West

Gibson Dunn

Greenberg Traurig

Gupta Wessler

Hogan Lovells

Holland & Knight

Jones Day

Kellogg Hansen

King & Spalding

Kirkland & Ellis

Labaton Sucharow

Latham & Watkins

Linklaters

Littler Mendelson

Locke Lord

Mayer Brown

Miles & Stockbridge

Morgan Lewis

Motley Rice

Murphy & McGonigle

Norton Rose Fulbright

Ogletree Deakins

Orrick Herrington

Osborne Clarke

Perkins Coie

Pinsent Masons

Proskauer Rose

Sandberg Phoenix

Sandler Reiff

Schlam Stone

Sidley Austin

Skadden

Tucker Ellis

Vinson & Elkins

Weil Gotshal

COMPANIES

American Express Company

American Federation of State, County and Municipal Employees

Apple Inc.

Aruba Networks, Inc.

Bristol-Myers Squibb Company

British Broadcasting Corp.

BuzzFeed Inc.

Center on Budget and Policy Priorities

Deutsche Bank AG

Digital Realty Trust Inc.

Discover Financial Services

Dunkin' Brands Group Inc.

Electronic Frontier Foundation

Ernst & Young

General Electric Company

Google Inc.

Microsoft Corporation

National Public Radio Inc.

National Right to Work Legal Defense Foundation

Nike Inc.

Robert Half International Inc.

Snap Inc.

Tax Foundation

The American Law Institute

Twitter Inc.

U.S. Chamber of Commerce

GOVERNMENT AGENCIES

Delaware Court of Chancery

Drug Enforcement Administration

European Commission

European Union

Federal Bureau of Investigation

Internal Revenue Service

National Labor Relations Board

New York State Department of Taxation and Finance

Securities and Exchange Commission

U.S. Attorney's Office

U.S. Department of Justice

U.S. Department of the Treasury

U.S. Environmental Protection Agency

U.S. House of Representatives

U.S. Supreme Court

World Trade Organization