Tax

  • October 4, 2017

    Amazon Hit With €250M Tax Bill By EU Antitrust Watchdog

    The European Commission ordered Luxembourg on Wednesday to recover €250 million ($294 million) in corporate income taxes from Amazon, finding that a tax ruling the country granted the retail giant amounted to anti-competitive state aid.

  • October 3, 2017

    Equifax Scores $7.25M Fraud Prevention Contract From IRS

    The Internal Revenue Service has hired Equifax to verify taxpayers' identities in a $7.25 million contract in which the government didn't consider other bidders, despite the company's involvement in a data breach that impacted 145 million people, the IRS confirmed Tuesday.

  • October 3, 2017

    Gov't Gets An Extra Year For Discovery In $20M Tax Fight

    A Utah magistrate judge on Tuesday granted the U.S. government’s bid to push discovery deadlines back by one year in a property dispute related to a $20 million tax suit, rejecting objections from landowners based on their contention that the government has already dragged out the process. 

  • October 3, 2017

    No One's Left To Sue IRS On Partners' Behalf, Tax Court Says

    The U.S. Tax Court on Monday granted the IRS a win against a group of limited partners seeking adjustments on their tax returns, saying no party with standing to pursue litigation on behalf of the defunct New Jersey partnership exists.

  • October 3, 2017

    Fla. Couple Can’t Shake $79M Tax Bill, 11th Circ. Says

    The Eleventh Circuit on Tuesday upheld a U.S. Tax Court decision finding a Florida couple liable for more than $79 million in unpaid taxes and interest from the sale of their telecommunications company using a so-called Midco transaction.

  • October 3, 2017

    SD Implores High Court To Kill Quill Precedent On Sales Tax

    The state of South Dakota implored the U.S. Supreme Court to reverse a 25-year rule preventing it from collecting sales tax from online retailers, saying in its petition Monday that the rule is incorrect and outdated, with detrimental effects on the economy.

  • October 3, 2017

    IRS To Appeal Loss In $234M Amazon Transfer Pricing Case

    The Internal Revenue Service has informed the U.S. Tax Court it intends to seek Ninth Circuit review of a March decision that handed the agency a stinging loss in its challenge to Amazon's valuation of assets transferred to a European subsidiary.

  • October 3, 2017

    Canadian Court Allows Extradition Of Tax Shelter Promoter

    A Canadian court has granted the U.S. government’s request to extradite a tax attorney who is facing charges back home accusing him of helping former partners of Ernst & Young LLP develop and market fraudulent tax shelters, while dodging more than $8 million in taxes himself.

  • October 3, 2017

    MassHousing GC Shifting To Taxable Loans Amid Low Rates

    While tax-exempt bonds have historically been a financing staple for affordable housing, funders in the field have had to shift their strategy as low interest rates on taxable bonds since the economic downturn have made their tax-exempt counterparts less attractive, MassHousing’s General Counsel Beth Elliott told Law360 in a recent wide-ranging interview.

  • October 3, 2017

    100 Groups Urge Opposition To GOP Territorial Tax System

    One-hundred groups, including the AFL-CIO and Americans for Tax Fairness, urged Congress Monday to oppose the "incredibly bad idea" of adopting a territorial tax system as part of the GOP’s tax reform framework, saying such a system would allow multinational corporations to repatriate foreign profits largely tax-free.

  • October 3, 2017

    Sens. Still Working On Stabilizing Health Insurance Markets

    A bipartisan deal could still materialize to stabilize the individual health insurance market, according to Senator Lamar Alexander, R-Tenn., who said Tuesday that lawmakers are trying to build support for a short-term fix.

  • October 3, 2017

    OECD Risk Guidance Conflicts May Spur Double Taxation

    Some countries are interpreting a paragraph in transfer-pricing guidance from the Organization for Economic Cooperation and Development as advocating a broad use of the profit-split method, which may result in double taxation, officials and tax practitioners said.

  • October 3, 2017

    OECD Handbooks Target Tax Avoidance By Multinationals

    The Organization for Economic Cooperation and Development has issued two new handbooks to help tax authorities implement and assess country-by-country tax reporting for large multinational companies, as part of its Base Erosion and Profit Shifting project aimed at cracking down on corporate tax-avoidance schemes worldwide.

  • October 2, 2017

    The Laterals Audit: Tax Attorney Moves In September

    In this latest edition of the Laterals Audit, two former government officials transitioned to private practice at Perkins Coie and KPMG, a deputy general counsel from the Illinois Department of Revenue joined Reed Smith in Chicago and Dechert LLP gained a commercial tax attorney in London.

  • October 2, 2017

    Inversion Rule Defeat May Impair Regulatory Process

    The U.S. Treasury’s power to issue immediately effective temporary regulations could be significantly weakened by a district court's invalidation of an Obama-era rule meant to crack down on U.S. companies moving their tax base overseas through a process called inversion.

  • October 2, 2017

    Justices Won’t Review Calif. Co.'s Taxable Connection Case

    The Supreme Court on Monday declined to hear a California-based nutrition supplement company’s argument that its mail-order business in Washington state did not create a taxable connection even where its wholesale channel did not establish or maintain a market for its retail side.

  • October 2, 2017

    Justices Decline Del. Trust’s Protest Of Ohio Tax Liability

    The U.S. Supreme Court declined Monday to review an Ohio Supreme Court decision finding that Ohio properly imposed income taxes on a Delaware trust’s sale of stock in a trucking logistics company that netted over $18 million.

  • October 2, 2017

    High Court Won’t Review Whether IRS Must Explain Tax Notice

    The U.S. Supreme Court on Monday declined to hear QinetiQ US Holdings Inc.’s challenge to a Fourth Circuit ruling that held the IRS does not have to provide an explanation for issuing a notice of tax deficiency.

  • October 2, 2017

    Continental Can't Escape Ponzi Coverage Suit

    Continental Casualty Co. and the receiver for a defunct company that ran a Ponzi-like real estate embezzlement scheme are headed to trial to decide whether a Continental policy covered some of the losses, after a California federal court denied dueling motions for summary judgment on Friday.

  • October 2, 2017

    IRS Delays Rules On Losses From Terminated Business Units

    The IRS announced Monday it is delaying by one year the effective date of regulations dealing with income and currency gains and losses for certain terminations of qualified business units, rules that are among those U.S. Treasury Secretary Steve Mnuchin had previously placed under scrutiny.

Expert Analysis

  • Making The IRS Portability Election Simpler

    Keri Brown

    A new IRS revenue procedure provides “ordinary millionaires” some regulatory relief with respect to making a portability election. This may have real value to a surviving spouse in offsetting a tax liability, say Keri Brown and Benjamin Cohen-Kurzrock of Baker Botts LLP.

  • Opinion

    It's Time To Improve Voir Dire In Federal Court

    Lisa Blue

    During the jury selection process, many times parties submit proposed voir dire questions, but the court ultimately chooses the questions to be asked and does all of the questioning of the jury panel. While this approach is judicially efficient, rarely do we learn anything meaningful from the panel members, say Lisa Blue of Baron and Blue and Robert Hirschhorn of Cathy E. Bennett & Associates.

  • Series

    Notes From A Law Firm Chief Privacy Officer: Insider Risks

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    As law firms hold sensitive information not only related to the firm but to the firm’s clients, an insider threat — whether it's a "bad actor employee" or inadvertent activity — poses a particular concern. There are steps that privacy officers can initiate to help minimize these threats, says Patricia Wagner, chief privacy officer for Epstein Becker Green.

  • Series

    Notes From A Law Firm Chief Privacy Officer: Balancing Act

    Kristin Jones

    As the role of law firm chief privacy officer becomes more prevalent and expansive, many CPOs are finding themselves in the midst of a delicate balancing act — weighing compliance with government regulations and client requirements on one side with the needs of firm business on the other, says Kristin Jones, chief privacy officer for Stradley Ronon Stevens & Young LLP.

  • How The IPad Can Be A Litigator's Best Friend

    Paul Kiesel

    New mobile computing tools — both hardware and applications — are changing the technology paradigm for legal practitioners. In particular, the combination of the 12.9-inch iPad Pro, the Apple Pencil and the LiquidText annotation app can revolutionize both trial preparation and courtroom litigating, says attorney Paul Kiesel, in his latest review of tech trends.

  • Series

    Notes From A Law Firm Chief Privacy Officer: CPO Vs. CISO

    Mark McCreary

    To understand the role of the law firm chief privacy officer — and why that person ought to be a lawyer — it’s important to distinguish the role they fill from that of the chief information security officer, says Mark McCreary, chief privacy officer for Fox Rothschild LLP.

  • 5 Questions To Ask Before Entering Joint-Representation AFA

    Natalie Hanlon Leh

    One growing trend is for clients to enter into alternative fee arrangements in which one law firm represents multiple parties who “share” fees and costs in a related matter. This way parties can more efficiently manage a matter and reduce their individual legal fees. But joint representation is not without its own risks and challenges, say attorneys with WilmerHale.

  • Legal Incubators Can Help New Lawyers And Society

    Martin Pritikin

    Legal incubators serve as an important bridge to practice and a crucial step toward aligning the incentives of new lawyers with the needs of their clients. They may even pose a threat to the traditional law school model itself, and that's not necessarily a bad thing, says Martin Pritikin, dean of Concord Law School at Kaplan University.

  • 4 Key Defenses In FBAR Liability

    Christopher Rajotte

    A U.S. person must file a Foreign Bank Account Report for offshore accounts with values exceeding $10,000 at any point during a given year. The first line of defense against an FBAR penalty is compliance with the filing obligation, but if a case is brought, several defense strategies are especially useful, says Chris Rajotte of Fuerst Ittleman David & Joseph PL.

  • Breaking Down Graham-Cassidy ACA-Replacement Proposal

    Eric Schillinger

    Following the Health Care Freedom Act’s defeat, the only remaining proposal to replace the Affordable Care Act that appears to have any chance of a Senate vote is a complex overhaul from Republican Sens. Lindsey Graham and Bill Cassidy, says Eric Schillinger of Trucker Huss APC.