The IRS has published guidance aimed at helping taxpayers determine foreign earnings and profits under the transition tax provision of the recently passed Republican tax overhaul, including what to do when a U.S. shareholder controls foreign corporations with multiple inclusion years.
PricewaterhouseCoopers LLP faces hundreds of millions of dollars in damages after a federal judge recently ruled its negligent audits of an Alabama bank contributed to one of the biggest bank failures of the financial crisis.
The New Year will likely see the U.S. Treasury Department issuing guidance for many new features in the Republicans' tax cut bill while it forges ahead with the Trump administration's deregulatory agenda. As practitioners eagerly await new and outstanding guidance, here are some significant policy changes that can be expected in 2018.
Retailers have survived another hectic holiday gifting season, but 2018 already is shaping up to keep them plenty occupied, from litigation seeking to let states collect sales tax from online retailers, to efforts by lawmakers to keep up with ever-increasing privacy and data security concerns. Here, Law360 looks at some of the most important cases, legislation and regulations retail experts will be keeping an eye on in the coming months.
U.S.-based multinational companies in 2018 will find themselves operating in the most uncertain tax climate in decades following the passage of the sweeping new Republican tax law.
The Republicans’ $1.5 trillion tax cut legislation has been identified as having multiple errors, ambiguities and unintended consequences that need to be corrected through future legislation, but fixing these problems is a politically vexing task that could leave unclear policies in place for taxpayers.
Familiar divisive tax issues will rear their complicated heads again in 2018 as federal courts are expected to address whether the Internal Revenue Code’s so-called omnibus clause goes too far, the IRS’ authority to issue rules under the Anti-Injunction Act and whether beverage giant Coca-Cola can escape a $3.3 billion tax assessment.
State legislative sessions, most of which begin this month, always create tax policy changes that require state tax agencies to issue guidance and regulations. But few state tax administrators have experienced anything like what is headed their way in 2018, as states deal with the effects of the massive tax overhaul Congress sent to President Donald Trump.
An income tax increase for millionaires, a minimum-wage hike and an effort to legalize recreational marijuana will likely be atop New Jersey officials' agenda in 2018 as Democrat Phil Murphy shakes up the state's political scene with his ascension to the governor's office in mid-January.
The ink on the newly enacted GOP tax reform bill will barely be dry as state legislatures get back to work in the new year and cities and states test new ways to bring in fresh revenue.
The Pennsylvania Supreme Court is gearing up for what attorneys say will be another busy year in 2018 as the justices face a string of high-profile appeals covering, among other issues, the authority of state environmental regulators to issue fines for ongoing pollution and attorney-client privilege in derivative disputes.
Fresh on the heels of arguably the most chaotic quarter that tax professionals have seen in years, practitioners already say they expect no slowdown in the torrent of news and high-impact decisions in the year to come.
President Donald Trump on Friday signed into law a massive overhaul of the U.S. tax code with major implications for businesses and individuals across the country. Here, Law360 looks at what effect some of those changes will have, including a comprehensive LexisNexis Legislative Analysis.
The newly enacted tax reform legislation signed Friday is likely to encourage companies to bring home much of the cash they've stashed overseas for years, but tax experts said it's likely their intellectual property will remain where it is, leaving a web of offshore entities in place.
The Texas Supreme Court affirmed a court of appeals ruling Friday, denying an Atlanta-based manufacturer’s $1 million refund claim based on its use of a multistate agreement’s three-factor apportionment formula, holding the apportionment of the Texas franchise tax is exclusively the province of Texas franchise tax law.
A new provision in the Republicans’ tax cut law takes away a favorable tax rate for innovators with self-created intellectual property, and the move could affect the sale of patented assets in deal-making ventures, especially in the technology and health care industries.
Even before the ink dried on President Donald Trump’s signature, which turned the massive federal tax overhaul bill into law Friday, some governors already had announced plans to mitigate its effects in their states.
The Texas Supreme Court on Friday declined to review a petition from an ex-client of Fried Frank Harris Shriver & Jacobson LLP who asked the court in October to reverse a decision that found Texas didn’t have jurisdiction over the firm in a suit alleging it gave flawed advice on a tax-sharing agreement it entered as part of a spinoff.
President Donald Trump signed the massive Republican tax bill into law Friday, marking the first major overhaul of the U.S. tax code in over 30 years.
The co-owner of a major New England seafood processor pled guilty on Thursday to evading about $1 million in taxes, but escaped steeper charges in what federal prosecutors called an extensive scheme involving three other executives, their wives and five shell companies to conceal millions of dollars in income.
Defending depositions is challenging. The lawyer is the only shield and protector for the witness and the client. The rules of engagement are less than clear, and fraught with ethical perils. Difficult judgment calls often must be made in the heat of battle. This is where lawyers really earn their keep, says Alan Hoffman of Husch Blackwell LLP.
There is a difference between a lawyer or investigator seeking evidence to defend against allegations and correct misrepresentations, and, on the other hand, using duplicitous means to gather information and intimidate alleged victims and journalists. Client advocacy does not mean winning at all costs, says Nicole Kardell of Ifrah Law PLLC.
Today's climate of “alternative facts” has jurors making decisions based on beliefs, emotions and social affiliations that often go unacknowledged or underappreciated. To present their case in the most persuasive manner possible, litigators should consider adapting to their audience when it comes to four psychological factors, say consultants with Persuasion Strategies, a service of Holland & Hart LLP.
The Republican tax proposal includes executive compensation tax reforms that would have significant implications for companies if enacted. Businesses should not redesign their 2018 bonus and incentive plans just yet, but they would be well-served to review the impact the bill would have if adopted in its current form, say attorneys with Cleary Gottlieb Steen & Hamilton LLP.
A South Dakota district court's recent decision in Flandreau v. Gerlach prevented the state's imposition of a use tax on purchases by nonmembers of goods and services at the tribe's on-reservation casino and related amenities. This case emphasizes the dual taxation problem that tribes should seek to have addressed through federal legislation once and for all, say Timothy Evans and Kathleen Nilles of Holland & Knight LLP.
Nothing has been more instrumental in my role as a legal recruiter than what I learned from a variety of hedge fund managers, venture capitalists and investment bankers — how to analyze a deal and make a decision quickly. It boils down to the traditional SWOT analysis, says Howard Cohl, director in Major Lindsey & Africa’s emerging markets group.
After much speculation, the GOP tax proposal unveiled last week makes no changes to the rules for retirement savings. Still, the estimated $115 billion per year of tax breaks for retirement accounts remains a tempting target for realization of tax savings needed to pay for Republicans' ambitious tax cut plans, says John Bartlett of Stites & Harbison PLLC.
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.