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Tax

  • May 14, 2018

    Tax Dodger Says Judge Erred In Justifying Record $10M Fine

    A Manhattan federal judge's "evolving explanation" for smacking wealthy tax cheat Morris E. Zukerman with a $10 million fine is based in factual error, the onetime Morgan Stanley banker's counsel told the Second Circuit Friday, asking for an order halting his $250,000 monthly fine payments pending the outcome of his appeal.

  • May 14, 2018

    Justices Reject Homeowners' Appeal Over Property Estimate

    The U.S. Supreme Court declined on Monday to hear an appeal over a Seventh Circuit ruling that found two Illinois women who spearheaded a campaign against township employees trespassing on private property can't pursue constitutional claims for an alleged unfair hike to their property assessment.

  • May 14, 2018

    EEOC Says It Needn't Fork Over More Docs To Strip Club

    The U.S. Equal Employment Opportunity Commission told a Florida federal court Friday that a strip club already has the available income information for a bartender applicant it allegedly discriminated against for being male and it is trying to compel more documents as a distraction.

  • May 14, 2018

    High Court To Hear If Damages For Rail Staff Can Be Taxed

    The U.S. Supreme Court agreed Monday to hear a petition from BNSF Railway Co. over whether payroll taxes should be deducted from compensation owed to a former employee for lost wages in connection with a workplace injury.

  • May 13, 2018

    Awaiting IRS Insight On Taxing Exec Pay, Cos. Craft New Plans

    The U.S. tax overhaul’s removal of performance-based pay as an exception to deduction limits on executive compensation is prompting some public companies to create new pay plans to ensure such incentives remain available, practitioners said at an American Bar Association conference Friday.

  • May 13, 2018

    Marinello Hasn't Put Brakes On Similar DOJ Pending Cases

    The federal government is continuing to prosecute cases under a section of the tax code despite a recent U.S. Supreme Court opinion knocking down its broad interpretation of the relevant clause, an official said Saturday.

  • May 12, 2018

    TCJA Provokes Questions About How To Define Entertainment

    The U.S. tax overhaul scrapped employer deductions for the cost of business-related entertainment but kept a partial deduction for meals, prompting practitioners at a tax conference hosted Saturday by the American Bar Association in Washington to ponder when, exactly, a meal might become entertainment.

  • May 12, 2018

    IRS To Start Enforcing Crypto Withholding Rule, Panelist Says

    The Internal Revenue Service will begin this year to more strictly enforce the requirement to withhold taxes for cryptocurrency payments to nonresident aliens, an attorney who has represented clients in related matters said at a Saturday tax conference in Washington, D.C.

  • May 11, 2018

    Tax Automation Co., Music Streamer File IPOs Totaling $265M

    A private equity-backed tax automation company and a Chinese music streamer filed initial public offerings Friday preliminarily intended to raise a combined $265 million, adding to the near-term pipeline of IPOs.

  • May 12, 2018

    Panelists Explore Guardrails For Partnership Representatives

    Given the potential unilateral power granted to the new role of partnership representatives during Internal Revenue Service examinations, experts at a tax conference Friday suggested that partnerships should consider carefully their representatives and the authority they’re granted.

  • May 11, 2018

    Wayfair Halted Online Tax Work, House Panel Counsel Says

    Congressional negotiators were working on a compromise solution for regulating online taxation when the U.S. Supreme Court agreed to review South Dakota v. Wayfair, which brought talks to a halt, the chief counsel to the House Judiciary chair said Friday.

  • May 11, 2018

    Taxation With Representation: Davis, Freshfields, Wachtell

    In this week’s Taxation with Representation, Takeda snapped up Shire for $62 billion, Vodafone bought a portion of Liberty Global’s European business for $21 billion, Nestle SA spent $7.1 billion on the marketing, sale and distribution rights for most of Starbucks’ retail and grocery store items and International Flavors and Fragrances acquired Frutarom for $7.1 billion.

  • May 11, 2018

    Bloomingdale's Taxes Wrong Bags Under City Law, Suit Says

    A purported class of Bloomingdale’s customers slapped the company with a lawsuit in Illinois state court Thursday over claims its Chicago stores are charging an illegal sales tax on its garment bags under a local ordinance they say applies only to paper and plastic checkout bags.

  • May 11, 2018

    FisherBroyles Picks Up DLA Piper Franchise Pro In Houston

    FisherBroyles LLP has snagged a former DLA Piper franchise partner with expertise stemming from in-house work, his own boutique and a decade in BigLaw to grow its Houston office.

  • May 11, 2018

    'Property Rights' Under Fraud Statutes Unclear, Justices Told

    A computer parts salesman has asked the U.S. Supreme Court to review the outcome of a Fifth Circuit decision upholding a 42-month conviction for money laundering and mail, wire and tax fraud, and provide clarity on what constitutes "property rights" under those criminal statutes.

  • May 11, 2018

    Health Hires: Katten, Seyfarth, Holland, Dechert, K&L Gates

    Katten Muchin Rosenman LLP, Garfunkel Wild PC, Seyfarth Shaw LLP, Holland & Knight LLP, Dechert LLP, K&L Gates LLP and Polsinelli PC are among the latest firms to have grown their health and life sciences abilities.

  • May 11, 2018

    Justices Urged To Skip Electric Co.’s $199M Deduction Appeal

    The IRS has insisted further review by the U.S. Supreme Court is not warranted for a lower court’s finding in support of the government in its denial of a $199 million tax deduction for a Pennsylvania-based electricity supplier, saying legal precedent was correctly applied and no circuit conflicts existed.

  • May 11, 2018

    IRS To Clarify Rules On Bonus Depreciation As Early As June

    Regulations to clarify eligibility for full bonus depreciation of property could be issued as early as June, according to an Internal Revenue Service official speaking Friday at an American Bar Association tax conference.

  • May 11, 2018

    ABA Seeks Clarity On New Exec Comp, Fringe Benefit Taxes

    Multiple American Bar Association committees are collecting public comments on the tax treatment of fringe benefits and compensation at nonprofits from the federal tax overhaul, a tax lawyer said Friday at an American Bar Association tax conference in Washington, D.C.

  • May 11, 2018

    Treasury Mulling Intermediate Sales Quandary On TCJA

    The U.S. Treasury Department is looking into whether incentives for exports in the recent federal tax overhaul apply to transactions that are required to go through an intermediary, such as arms sales to foreign buyers, an official said at a conference Friday.

Expert Analysis

  • Fine-Tuning The New Partnership Audit Regime

    Kat Saunders Gregor

    The federal omnibus appropriations bill enacted in March included several helpful technical corrections to the new partnership audit rules. One provision, aimed at reducing litigation, broadened the scope of the partnership audit regime and may influence the future of partnership tax controversy matters, say Kathleen Gregor and Brittany Cvetanovich of Ropes & Gray LLP.

  • Planning For New IRC Section 1061: Part 2

    Scott Dolson

    The views of tax professionals and the IRS interpreting Internal Revenue Code Section 1061 are rapidly evolving in the aftermath of hurriedly adopted legislation. While future corrective legislation and agency interpretations may target planning, the statute in its current form provides opportunities for taxpayers to work around the negative consequences of the new three-year holding period for certain carried interests, say attorneys at Frost Brown Todd LLP.

  • Structuring Life Settlements Investment Funds After TCJA

    Brian Casey

    The Tax Cuts and Jobs Act should be carefully evaluated by offshore life settlements investment vehicles, as it may negatively impact U.S. income tax consequences for U.S. shareholders, who should consider structuring or restructuring funds to minimize these adverse income tax effects, say attorneys with Locke Lord LLP.

  • Florida Taxpayer Advocate Office Gains New Independence

    Mark Holcomb

    Recent changes by the Florida Legislature provide an opportunity for the state's taxpayer rights advocate to become a voice for all taxpayers — not just those in dire straits — and spur meaningful reforms, says Mark Holcomb of Dean Mead & Dunbar.

  • Supporting Nontraditional Data Types In E-Discovery

    Jason Paroff

    The advancement in connected technologies and software has created an explosion of nontraditional data sources that present challenges to e-discovery practitioners. Many tools and techniques used to process traditional data may not be practical for these new data types, say Jason Paroff and Sagi Sam of Epiq.

  • Planning For New IRC Section 1061: Part 1

    Scott Dolson

    Recently enacted Internal Revenue Code Section 1061 makes several important modifications to the beneficial tax treatment of carried interest. Professionals in the hedge fund, private equity or real estate industries need to keep this new provision in mind when structuring their compensation arrangements, say attorneys at Frost Brown Todd LLC.

  • How Tax Authorities Are Responding To Cryptocurrency

    Mark Rush

    The features that make cryptocurrencies attractive to their users — relative anonymity and mobility — have created heightened concerns among tax agencies in the U.S. and abroad. Providers of financial services to cryptocurrency holders should take steps to ensure that they are not enabling tax evasion, say members of K&L Gates LLP and Navigant Consulting Inc.

  • The Myth Of Corporate Tax Residence

    David Elkins

    Numerous commentators have argued that the problem behind the maladies of the current international corporate tax regime is a flawed definition of corporate residence. However, such an assumption is unwarranted as tax residence is an attribute of individuals only, inapplicable to the corporate entity, says David Elkins of Netanya College.

  • NJ Real Estate Considerations After Cannabis Legalization

    Christopher Stracco

    Given New Jersey's unique real estate regulatory regimen, the likelihood of cannabis legalization raises many legal considerations that will impact everything from property taxation to regulation of dispensary outlets, say attorneys with Day Pitney LLP.

  • Series

    State Tax After TCJA: Blue States' Deduction Strategies

    Gary Botwinick

    What do you do when it seems that Washington is out to get you? If you are a lawmaker or governor in New York, California, New Jersey or any of several other blue states that relies on significant income or property taxes to pay your state’s bills, you get creative, says Gary Botwinick of Einhorn Harris Ascher Barbarito & Frost PC.