U.S. multinational businesses seeking pre-emptive IRS approval regarding their tax treatment of intercompany transactions must compile “very thorough and careful” descriptions of the facts, the agency said in recently released guidance, which notes that taxpayers can accordingly choose to limit what’s covered in an advance pricing agreement.
Fannie Mae and Freddie Mac have pushed the Seventh Circuit to reconsider its decision to dissolve an injunction barring the collection of local taxes from Chicagoans who purchased property from them, arguing the court’s finding misconstrues the plain text of government federal tax-exemption statutes.
The first battle in the government's case against Paul Manafort will center on the unusual "no-knock" raid of the former Trump campaign chairman’s home in July, but his attorneys will have a hard time arguing the special counsel’s team acted in bad faith, despite a few recent rulings striking down aggressive searches.
An Illinois man has copped to a charge related to his purported role in laundering money that scammers at call centers in India fraudulently obtained from American victims by pretending to be Internal Revenue Service agents and other government officials, Texas federal prosecutors announced Monday.
The Senate Finance Committee modified its tax plan late Tuesday to repeal the Affordable Care Act’s individual mandate and sunset a number of individual tax provisions, including the estate tax exemption, to meet a budgetary requirement to not increase the deficit after 10 years.
An investment firm organized in the British Virgin Islands has asked multiple federal courts to block the IRS’ bid to obtain its records from several banks, saying the records are irrelevant and the requests circumvent procedural safeguards.
The Tax Cuts and Jobs Act, approved by the House Ways and Means Committee Nov. 9, will add a further $3 trillion to the federal debt burden between 2028 and 2037, according to a report by the Center on Budget and Policy Priorities released Monday.
A Massachusetts federal court Monday found the U.S. government was entitled to recover nearly $7.8 million transferred to a church in an attempt to fraudulently conceal assets from collection following a taxpayer’s criminal fraud conviction.
HSBC Holdings PLC has agreed to pay €300 million ($353 million) to settle a longstanding investigation launched by French authorities into allegations it helped clients evade taxes via its Swiss private-banking unit, the lender said on Tuesday.
The European Court of Justice has been asked to decide whether the European Union's cross-border working regulations could supersede national rules that prevent professionals working abroad from applying home tax levels to their pension contributions.
The European Union must swiftly adopt reforms to stamp out corporate tax avoidance by the end of the year, Europe’s tax commissioner said on Tuesday as he called on member states to agree on a blacklist of offshore havens by December.
Lawmakers urged Britain’s government on Tuesday to implement new laws to force multinational businesses to fully report their activities and profits and to punish bankers and lawyers for helping them to avoid paying tax.
A gaming reform bill filed in the Florida Senate on Monday takes a more narrow approach than the ambitious but unsuccessful efforts of recent years, but an anti-gaming group said provisions paving the way for fantasy contests and so-called designated player games raise major concerns.
As the House and Senate tax bills hurtle through congressional committees with amendments to bring them in line with budgetary rules, a number of policy proposals may end up being decided, not on their merits, but by how they will impact the country’s approximately $20 trillion debt.
Democrats on the Senate Finance Committee accused their Republican colleagues Monday of shutting them out of the tax reform process during the opening hearing for a bill that would slash $1.5 trillion in taxes over the next decade.
The U.S. government can’t shield records documenting the Internal Revenue Service’s alleged about-face on a legal question involving the deductibility of certain losses, a Texas magistrate judge has ruled, finding that the information could shed light on Anadarko Petroleum Corp.’s $25 million tax refund suit.
Companies that use one of the Big Four accounting firms are more likely to allocate income to alleged tax havens — even if they don't use the firms for tax planning, according to a study released Monday by activist group Tax Justice Network.
A recent report by the Joint Committee on Taxation found that the Senate Republicans' tax overhaul bill would deplete federal coffers by slightly less than the $1.5 trillion limit for passing the measure under fast-track rules, but additional revenue losses after 10 years could still present a roadblock.
Just days after the Senate unveiled its version of tax reform legislation, House Ways and Means Committee Chairman Kevin Brady said the measure wouldn’t pass in the lower chamber unless it includes some level of relief for property taxes.
New limits on like-kind transactions proposed in House and Senate legislation to overhaul the tax code could inspire sell-offs of assets such as art, horses, cars and airplanes, but another provision in the bill could ease the transition to the new rules.
When considering a lease, tenants should closely examine whether the property is in transition, under construction or being repurposed, in order to address concerns regarding anomalous real estate tax escalations, says Dena Cohen of Herrick Feinstein LLP.
As law firms begin preparing for their annual budget review, Steve Falkin and Lee Garbowitz of HBR Consulting discuss why firm leaders should give their internal information technology and procurement teams a seat at the table.
While Republicans’ false starts this year on health care reform illustrate that advancing legislation is challenging, there seems to be growing consensus on the urgency for tax reform. But there are many surprises in the draft legislation, and the details are almost certain to cause controversy, say attorneys with BakerHostetler.
Unclaimed property audits have occurred in all economic sectors in 2017. While states continue to press their audits forward, recently enacted legislation has rewritten the rules in this already uncertain area. Companies under audit confront difficult choices, while those companies not (yet) under audit face an uncertain risk and compliance situation, say Mary Jane Wilson-Bilik and Wilson Barmeyer of Eversheds Sutherland LLP.
Artificial intelligence needs to be legally defensible in order to be useful to law firms. There are requirements for making this happen, says Mark Williamson, co-founder and chief technology officer of Hanzo Archives Ltd.
The long litigation life cycle for large, complex civil lawsuits provides ample time for clients and counsel to form strong opinions — often negative when based on adversarial exchanges — about the opposing trial team, their witnesses and their experts. Martha Luring of Salmons Consulting shares some common perceptions not always shared by jurors.
A few jurists and commentators have recently caused a stir in the e-discovery community by arguing that litigants should avoid using keyword searches to filter or cull a document population before using predictive coding. This “no-cull” rationale undermines the principle of proportionality at the heart of the recent changes to Federal Rule 26, say John Rosenthal and Jason Moore of Winston & Strawn LLP.
By "unicorn" I don’t mean the next great tech startup with a valuation of $1 billion. I mean the new breed of lawyers realizing that there are better ways to get their day jobs done, says Lucy Endel Bassli, assistant general counsel leading the legal operations and contracting functions at Microsoft Corp.
Amazon's competition for its second headquarters has garnered great interest and attention. The seven-page request for proposals may be short, but it shares certain key similarities with an RFP issued under the Federal Acquisition Regulation, say attorneys with Steptoe & Johnson LLP.
As widespread claims of sexual misconduct continue to surface in the entertainment industry and beyond, a discussion of how judges treat workplace discrimination cases may be particularly timely. Here, U.S. District Judge John McConnell reviews the book "Unequal: How America’s Courts Undermine Discrimination Law," by professors Sandra Sperino and Suja Thomas.