• March 9, 2018

    ‘Tax Extender’ Process Must Change, Congress Staffers Say

    Congress must get off the merry-go-round of renewing targeted tax benefits every year or two because it makes for bad policy and increases uncertainty for businesses, staffers for the U.S. House and Senate tax committees said Friday.

  • March 9, 2018

    SALT: Still Crazy After All These Years

    While South Dakota v. Wayfair has reignited the love Quill, hate Quill, save Quill, kill Quill saga on the public stage, it is far from the only tax dispute worth following. From baseball to lonesome income with no tax home, Quarles & Brady LLP partner David Brunori breaks down the most noteworthy ongoing state and local tax controversies.

  • March 9, 2018

    Taxation With Representation: Wachtell, Skadden, Baker

    In this week’s Taxation with Representation, Cigna bought Express Scripts for $67 billion, GTCR LLC and Sycamore Partners took CommerceHub private in a $1.1 billion deal and AXA Group acquired XL Group Ltd. for $15.3 billion.

  • March 9, 2018

    EU Probes UK 'Zero VAT' Tax On Commodity Derivatives

    The European Commission is investigating whether the British government is infringing European law over the way it taxes some commodity derivatives when they are traded on an exchange, HM Treasury said on Friday.

  • March 8, 2018

    Manafort Pleads Not Guilty, Again Ordered Confined To Home

    U.S. District Judge T.S. Ellis III placed a second order for home confinement and GPS electronic monitoring on former Trump campaign manager Paul Manafort, who pled not guilty in Virginia federal court Thursday to last month's indictment for tax violations, bank fraud and failure to report foreign accounts by Special Counsel Robert Mueller.

  • March 8, 2018

    Importer, Cigar Co. Denied Dismissal Of $3M Tax Suit At CIT

    The Court of International Trade denied bids by a cigar company and an importer to dismiss claims they failed to pay more than $3 million in excise taxes on cigars imported from the Dominican Republic on Wednesday, saying the federal government has sufficiently pled its case.

  • March 8, 2018

    Ohio Suit Against Soccer Team Tests Anti-Relocation Law

    The state of Ohio and city of Columbus are going to court to keep the Columbus Crew Major League Soccer club from leaving the city, a suit that could test the bounds of an Ohio state law and have broader implications for the states and cities in danger of losing a professional sports team to relocation.

  • March 8, 2018

    US' Position That Quill Isn't Important Raises Eyebrows

    Solicitor General Noel Francisco defied conventional wisdom Monday when, representing the official position of the United States, he told the U.S. Supreme Court that Quill Corp. v. North Dakota isn’t really so important in online taxation.

  • March 8, 2018

    Reader's Digest Publisher Hits Back In 2nd Circ. Tax Bout

    The publisher of Reader’s Digest has slammed the government’s argument against its bid to recover $2.1 million in tax deductions, telling the Second Circuit that the government’s position was arbitrary and contrary to statutory language.

  • March 8, 2018

    Transfer Pricing Will Still Be Enforced, IRS Official Says

    Even though the U.S. has shifted to a territorial tax system, in which only local income from a source inside a country is taxed, the Internal Revenue Service will keep enforcing transfer pricing, an IRS official said on Thursday.

  • March 8, 2018

    Ga. Partnership Fights $8.6M Tax Donation Denial By IRS

    A Georgia partnership is asking the U.S. Tax Court to allow an $8.6 million deduction for donating a land conservation easement over 411 acres, claiming the IRS denied the deduction without reason.

  • March 8, 2018

    Sen. Wyden Slams Push To Add Remote Sales Tax To Bill

    Senate Finance Committee ranking member Ron Wyden said Thursday he was "extremely concerned" about reports that Republicans intended to address remote sales tax collection on a national level in legislation they were trying to include in a must-pass federal spending bill.

  • March 8, 2018

    Reed Smith Nabs Ex-Calif. Tax Agency Counsel As Partner

    Reed Smith LLP Thursday announced the addition of Shail Shah as a partner in the firm’s state tax practice in Los Angeles, bringing the state tax team up to 40 lawyers.

  • March 8, 2018

    NY Senator Pitches 8.5% Tax On Casinos' Sports Revenue

    New York state Sen. John Bonacic introduced a bill Wednesday that would regulate sports betting and mobile sports wagering in the state, calling for regulation of pro and college sports and proposing an 8.5 percent tax on casinos' sports wagering gross revenue.

  • March 8, 2018

    Ala. Man Gets 30 Years For ID Theft, $22M Tax Fraud

    An Alabama man found guilty of defrauding the government as part of an identity theft ring that sought more than $22 million in fraudulent tax refunds was sentenced Thursday to 30 years in prison, according to an announcement from the U.S. Department of Justice.

  • March 8, 2018

    Pot Business Asks 10th Circ. For Equal Treatment From IRS

    A Colorado marijuana dispensary asked the Tenth Circuit on Wednesday to stop the IRS from investigating businesses for criminal activity and to overturn a tax code provision disallowing business deductions for the sale of medical marijuana.

  • March 8, 2018

    Rival 'O'Keefe' Law Firms Settle Trademark Fight

    Two small Chicago law firms, both named "O'Keefe" and both focusing on tax law, reached a settlement Wednesday to end a trademark fight over their shared use of the surname.

  • March 7, 2018

    France Can't Deny Energy Co. Tax Exemptions, EU Court Says

    Supplies such as natural gas that are used to generate both heat and electricity should get the same tax exemption as fuel that produces a single form of energy, the European Union’s top court ruled on Wednesday, rejecting France’s differing take on European law.

  • March 7, 2018

    Coke CEO Defends Foreign Licensees In $3.3B Tax Court Trial

    The CEO of Coca-Cola Co. said on Wednesday the company's foreign licensees were autonomous entities that made key business decisions, disputing the Internal Revenue Service's characterization of them as mere conduits for profit shifting, during the third day of a $3.3 billion transfer pricing trial at the U.S. Tax Court.

  • March 7, 2018

    7th Circ. Says Ill. Man Can't Withdraw Tax Evasion Plea

    An Illinois man lost a bid to withdraw his guilty plea for wire fraud and tax evasion after the Seventh Circuit ruled on Wednesday that his attorney had made reasonably strategic decisions in representing him.

Expert Analysis

  • An Overview Of The New International Tax Provisions

    Understanding The New International Tax Provisions

    The new tax law made significant international tax changes that affect both U.S. and foreign-parented multinational corporations. In this video, Carol Tello and Lauren Stewart of Eversheds Sutherland LLP provide an overview of the law and its impact, including the reduced corporate tax rate, the shift to a hybrid territorial/worldwide system and the base erosion provisions.

  • Series

    Judging A Book: Duncan Reviews 'Justice And Empathy'

    Judge Allyson Duncan

    In "Justice and Empathy: Toward a Constitutional Ideal," the late Yale Law School professor Robert Burt makes a compelling case for the undeniable role of the courts in protecting the vulnerable and oppressed​. But the question of how the judiciary might conform to Burt’s expectations raises practical problems​, says U.S. Circuit Judge Allyson Duncan of the Fourth Circuit. ​

  • SEC, CFTC Whistleblowers Dodge A Devastating Tax Bullet

    Gary Aguirre

    Before the brief government shutdown last week, whistleblowers destined to receive bounties from the U.S. Securities and Exchange Commission and the U.S. Commodity Futures Trading Commission faced devastating tax liability. But the act that reopened the government vaporized the bullet about to strike this narrow class of whistleblowers, says Gary Aguirre, a former SEC staff attorney.

  • A Recent Tax Court View Of Statute Of Limitations Provisions

    Andrew Roberson

    The U.S. Tax Court opinion in Rafizadeh v. Commissioner clarifies Internal Revenue Code Section 6501(e)(1)(A)(ii) and sheds light on the IRS approach to interpreting statute of limitations provisions, say Andrew Roberson and Elizabeth Chao of McDermott Will & Emery LLP.

  • The Art Of The Litigation Funding Deal

    Julia Gewolb

    As litigation funding becomes more widespread, greater complexity and variability in funding deals are to be expected. All claimants should consider certain key questions on the economics of single-case funding when considering or comparing funding terms, says Julia Gewolb of Bentham IMF.

  • TCJA Will Affect Foreign Investments In US Real Estate

    Brad Wagner

    The Tax Cuts and Jobs Act signed into law last December has significant ramifications for foreign investors utilizing the blocker corporation structure. Moving forward, tax planning and tax projections for the life of a deal will be required to minimize income taxes, say Brad Wagner and Justin Wood of Wagner Duys & Wood LLLP.

  • Smart Contracts Need Smart Corporate Lawyers

    Matthew O’Toole

    Given the operational and security risks involved, and the substantial digital asset values transacted, the rise of distributed ledger technology and smart contracts will create new opportunities and responsibilities for transactional lawyers, say attorneys with Potter Anderson Corroon LLP.

  • Tax-Exempt Organizations Face A New Excise Tax

    James Malone

    For tax-exempt organizations, the Tax Cuts and Jobs Act included a key change: There is now an excise tax applicable to exempt organizations on “excess” executive compensation, according to James Malone, leader of Post & Schell PC’s tax controversy practice.

  • A Look At Hong Kong's New Transfer Pricing Proposal

    Steven Sieker

    While transfer pricing is not a new concept in Hong Kong, the government recently proposed the codification of transfer pricing principles into law — which would impose legally binding obligations on multinational companies. It also signals Hong Kong's intention to increasingly and more aggressively enforce the arm's length principle, say members of Baker McKenzie.

  • How To Fix Your Broken Client Teams

    Mike O'Horo

    Law firms claim they create client teams to improve service. Clients aren’t fooled, describing these initiatives as “thinly veiled sales campaigns.” Until firms and client teams begin to apply a number of principles consistently, they will continue to fail and further erode clients’ trust, says legal industry coach Mike O’Horo.