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Tax

  • September 25, 2018

    'Unicorns' Boost IPO Proceeds Amid Global Slowdown

    Despite a drop in global initial public offerings amid geopolitical tensions and trade uncertainties, U.S. activity has remained strong through the first nine months of 2018, aided by the rise of so-called unicorn IPOs, according to a report released Tuesday by a Big Four accounting firm.

  • September 25, 2018

    4 Things Benefits Attys Need To Know About Tax Reform 2.0

    As a new round of tax-reform proposals winds its way through Congress, flush with plans to alter the ways Americans save for retirement, benefits attorneys should pay attention to provisions that would protect closed pension plans, relax benefit-distribution requirements and promote the spread of “association retirement plans," experts say. Here, Law360 breaks down these proposals.  

  • September 24, 2018

    Costco Customers' Tax Overcharge Suit Tossed By NY Court

    A New York federal judge on Monday granted Costco's bid to toss an amended potential consumer class action alleging the big-box retailer overcharged customers on sales taxes under Empire State tax law, saying the suit is better lodged with the New York Tax Commission.

  • September 24, 2018

    Senate Democrats Try To Force Vote On 'Dark Money' Rule

    Two U.S. Senate Democrats introduced a resolution Monday that could bring a vote before the chamber on legislation to overturn the U.S. Department of the Treasury's recent “dark money” guidance.

  • September 24, 2018

    Ex-Ad Exec Wins Appeal For $10M Tax Refund In 9th Circ.

    A former ad agency executive won his appeal for more than $10 million in tax refunds when the Ninth Circuit ruled Monday that he had fulfilled a legal requirement to report inconsistencies between his personal tax return and that of his now-defunct advertising placement company.

  • September 24, 2018

    PwC, Fragomen Ink Global Immigration Partnership

    Global immigration firm Fragomen, Del Rey, Bernsen & Loewy LLP will enter into a strategic partnership with the U.K. arm of PricewaterhouseCoopers to integrate and cross-market their tax, mobility and immigration services, the firms announced Monday, in a move that furthers the Big Four accounting firms' push into the domain of traditional law firms.

  • September 24, 2018

    Tribe Slams Wash. For 'Christian Discovery' In Fuel Tax Row

    The Yakama Nation urged the U.S. Supreme Court on Monday to uphold a ruling that a tribal fuel distributor doesn't have to pay a Washington state tax, saying the state is "wielding the sword of the religious, racist, genocidal, fabricated doctrine of Christian discovery" to try to undermine the tribe's treaty rights.

  • September 24, 2018

    PR Firm Ex-CFO Admits Skimming But Disputes By How Much

    The former chief financial officer for an international marketing and public relations firm pled guilty to an embezzlement scheme that prosecutors say cost the four companies he worked for more than $3.8 million, even as he took issue with many of the specific allegations laid out during a hearing Monday in Massachusetts federal court.

  • September 24, 2018

    3rd Circ. Revives FDCPA Suit Over IRS Reporting Language

    A statement in debt collection letters saying forgiveness of the debt may be reported to the IRS could constitute a violation of the Fair Debt Collection Practices Act because the debts in question were too small to be reported, the Third Circuit in a precedential opinion ruled on Monday in reviving a potential class action against Midland Credit Management Inc.

  • September 24, 2018

    Seyfarth Escapes Illegal Tax Shelter RICO Suit

    An Illinois federal judge has dismissed a Racketeer Influenced and Corrupt Organizations Act suit accusing Seyfarth Shaw LLP of selling a client an illegal tax shelter, saying that the man had failed to establish that the alleged fraud was part of the firm’s usual way of doing business or that it was an ongoing practice.

  • September 23, 2018

    Financial Secrecy In US, EU More Harmful Than Havens: Report

    Tax havens blacklisted by the European Union enable only 1 percent of the financial-secrecy services that threaten EU countries, while one-third comes from financial centers within the 28-nation bloc, an advocacy group asserted in a new study.

  • September 21, 2018

    Jury Finds Overstock.Com Guilty Of $3M Escheat Holdback

    A Delaware jury took little more than a hour to find Overstock.com guilty of concealing nearly $3 million in abandoned gift card balances from Delaware’s revenue agency, after a six-day whistleblower trial that could lead to a treble damages sanction.

  • September 21, 2018

    Ex-Chevron Oil Trader Gets Probation For Tax Fraud

    A former oil trader for Chevron facing 20 years in prison for his role in an alleged kickback scheme until making a deal with prosecutors was sentenced by a federal judge in Houston on Friday to three years of probation.

  • September 21, 2018

    Easing Of Debt-Equity Regs Won’t End Need For Documentation

    The U.S. Department of the Treasury plans to do away with rules forcing multinational corporations to prove related-party transactions are debt as opposed to equity, but thorough documentation still could prove beneficial in case of an audit.

  • September 21, 2018

    IRS' Decision To Delay New W-4 Form Necessary, Tax Pros Say

    The Internal Revenue Service’s decision to delay carrying out a new W-4 form was both necessary and positive, tax and payroll professionals told Law360 Friday.

  • September 21, 2018

    Co. Still Liable If Worker Lies That Taxes Paid: 8th Circ.

    A company misled by an errant employee into thinking he paid its taxes is still liable for interest and penalties when he didn’t, the Eighth Circuit said in an opinion Friday upholding a lower-court dismissal.

  • September 21, 2018

    Atlantic City's Woes Stem From Relying On Casino Tax: Report

    A report by the state of New Jersey has outlined the history and causes of Atlantic City's financial woes, linking its problems to the city's reliance on casino tax revenues, and recommended imbuing the tax assessor with more power.

  • September 21, 2018

    In 3 Years Since BEPS, Most IP Regimes In Compliance

    Three years after the Organization for Economic Cooperation and Development came out with its base erosion and profit shifting plan, most tax incentives regimes for intellectual property development are now compliant, signifying that, as one OECD official said, “everybody is moving in the right direction.”

  • September 21, 2018

    Houston Atty Charged In $18M Offshore Tax Evasion Scheme

    A Houston attorney has been indicted in a Texas federal court on charges of conspiracy and tax evasion for his role in a scheme to repatriate more than $18 million in untaxed earnings from the Isle of Man, according to the U.S. Department of Justice.

  • September 21, 2018

    Taxation With Representation: Gibson, Hogan Lovells, Mayer

    In this week’s Taxation with Representation, Enbridge simplified its corporate structure with $7.1 billion in deals, Adobe bought Marketo for $4.75 billion, Univar snapped up Nexeo for $2 billion, and Western & Southern Financial Group acquired Gerber Life Insurance for $1.6 billion.

Expert Analysis

  • In Calif., Questions Remain On Law Firm Conflict Waivers

    Richard Rosensweig

    In Sheppard Mullin v. J-M Manufacturing Co., the California Supreme Court ruled last month that a law firm's failure to disclose a known conflict with another current client did not categorically disentitle the firm from recovering fees. But the court didn’t provide hoped-for guidance on how to write an enforceable advance conflict waiver, says Richard Rosensweig of Goulston & Storrs PC.

  • Q&A

    A Chat With Faegre Client Development Chief Melanie Green

    Melanie Green

    In this monthly series, Amanda Brady of Major Lindsey & Africa interviews management from top law firms about the increasingly competitive business environment. Here we feature Melanie Green, chief client development officer at Faegre Baker Daniels LLP.

  • Illinois Tax Talk: Penalties In Chicago And Cook County

    Samantha Breslow

    Although the basis for relief from tax penalties is similar for Illinois, Cook County and Chicago, there are key differences in the procedure and requirements for seeking penalty abatement between the state and local levels, says Samantha Breslow of Horwood Marcus & Berk Chtd.

  • Unpacking The New Temporary Rules For Bonus Depreciation

    Ellen McElroy

    Last year’s business-friendly amendment of Internal Revenue Code Section 168(k), which allows immediate expensing for certain business assets, left many questions. In August, the Department of Treasury proposed rules clarifying requirements for depreciable property, but not all solutions are permanent and many issues remain unresolved, say attorneys at Eversheds Sutherland LLP.

  • A Look At New IRS Guidance For Nonprofits Calculating UBTI

    Shira Helstrom

    The Tax Cuts and Jobs Act imposed an additional administrative burden on tax-exempt organizations by eliminating their ability to aggregate unrelated trade and business income activity. Since the IRS issued guidance and interim rules in August, organizations should find compliance easier and also consider whether additional efficiencies might be possible, says Shira Helstrom of Morgan Lewis Bockius LLP.

  • Fundamental Valuation Principles Prevail In Minn. Tax Court

    Mark Lansing

    In Enbridge Energy v. Commissioner of Revenue, the Minnesota Tax Court recently rejected the state revenue commissioner’s attempt to artificially increase an interstate pipeline’s value to exceed market value. Whether by the misuse of unit valuation or asset valuation, taxing jurisdictions continue to find ways to overstate the value of energy-related property, says Mark Lansing of Dickinson Wright PLLC.

  • M&A Structuring And Due Diligence After Tax Reform

    Taylor Kiessig

    While the Tax Cuts and Jobs Act did not change what constitutes a tax-free reorganization, it is having a significant impact on domestic and cross-border mergers and acquisitions. Attorneys at Eversheds Sutherland LLP consider how the changes affect transaction structuring, diligence and tax risk allocation in M&A transactions.

  • Canadian Holding Structure Saves On Tax, For Now

    Greg Johnson

    The Tax Court of Canada, taking a commercially realistic approach, held in Alta Energy Luxembourg v. The Queen that a limited liability company was entitled to treaty benefits on capital gains and that the general anti-avoidance rule did not apply to the disposition of shares of a Canadian resource company. However, it is expected that the multilateral instrument and principal purpose test could curtail the use of these types of structures, say Greg Johnson and Wade Ritchie of Bennett Jones LLP.

  • Grandfathering Executive Compensation Plans Under TCJA

    Eric Winwood

    While the Tax Cuts and Jobs Act fundamentally changed rules governing the deduction under IRC Section 162(m) of executive compensation by publicly held corporations, it also included grandfather relief for some existing arrangements. Eric Winwood of Baker Botts LLP discusses the recent grandfather relief guidance and its effects.

  • 10 Questions For Upcoming Opportunity Zone Guidance

    Marc Schultz

    Last year's tax overhaul created an incentive program to encourage the investment of private capital in certain "opportunity zones" throughout the United States. The IRS is expected to issue guidance for interpreting many of the opportunity zone provisions in short order. However, the success of this program could depend upon the IRS' answers to these 10 questions, says Marc Schultz of Snell & Wilmer LLP.