What is a hostile work environment?
CorpCast Episode 8: The Controlling Stockholder
From Behind the Bribe: The Sharp End of Compliance
Strong Market Outlook Drives Growth of Philippine Companies
Why do we have to go to mediation?
FCPA Compliance and Ethics Report-Episode 178-Ben Locwin on Risk Assessments
Do I need an expert witness in my case?
Marketing to Millennials
CorpCast Episode 7: Better Know a Judge: the Honorable Mary M. Johnston of the Delaware Superior Court
Top Three Cybersecurity Misconceptions
Preparing a Company to Deal With Activist Investors
How can someone prepare for the first meeting with an attorney?
CorpCast Episode 6: A Brief Introduction to the Delaware Rapid Arbitration Act
The Intersection of Cyber and D&O Coverage
Talking PTAB with Bob Steinberg
Is Private/Non-Profit D&O Coverage Under Priced?
CorpCast Episode 5: The eDiscovery Big Picture
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Richard Bistrong Weighs in on the FIFA Scandal and Takedowns
Meritas Capability Webinar - Avoiding Common Mistakes Companies Make When Operating a Business Aircraft
Though in the midst of a stifling budget and personnel reduction, the United States Internal Revenue Service (“IRS”) recently announced an increased effort to curb what it sees as widespread abusive applications of so-called...more
On May 26, 2015, the United States Court of Appeals for the District of Columbia upheld a District Court decision and ruled that the Internal Revenue Service could not impose excise tax on certain wholly-foreign retrocessions...more
The Internal Revenue Service (IRS) recently issued proposed regulations addressing what constitutes the “active conduct of an insurance business” for purposes of the passive foreign investment company (PFIC) rules (the...more
On April 21, 2015, the Minister of Finance presented Canada’s long-awaited 2015 Federal Budget (the 2015 Budget). The 2015 Budget includes a number of taxpayer-friendly measures, including limited relief from Canadian source...more
Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more
In This Issue:
- Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers
- When Is a Second Inspection Not a Second Inspection?
- Captive Insurance Litigation: Key 2014 Cases
Case Updates -
Court finds ownership of LLC membership interest does not constitute doing business in California On November 14, the Fresno County Superior Court determined that Swart, an Iowa-based corporation with a...more
Is a quiet or silent trust illusory? The question is intentionally ambiguous. Is the question whether the trust itself is illusory, or just its quietness? A quiet or silent trust has been defined as “an irrevocable trust...more
In January, New York Governor Andrew Cuomo proposed broad corporate tax reform in his budget bill, which is currently winding its way through the legislature. The most significant proposal is a shift from a separate entity...more
Wide ranging changes to the way in which LLP members are taxed are due to take effect on 6 April 2014. LLPs and their members, particularly those in professional service and private equity/fund management firms, should,...more
In Wendy’s International, Inc. v. Brian Hamer, decided earlier this week, the Illinois Appellate Court found that Taxpayer had met its burden and proved that its subsidiary insurance company was a bona fide insurance company...more
Life insurance and irrevocable trusts are great tools to ease family business succession issues and mitigate exposure to shareholder oppression and disputes. Irrevocable life insurance trusts (ILIT), in particular, play an...more
With insurance premiums on the rise and the uncertain state of the federal tax system, middle market business owners may be looking for a source of stability that allocates the risks associated with operations. A “small”...more
In This Issue:
Making the ‘Right’ Choice; Top Ten Mistakes Businesses Make Regarding Insurance; and You’ve Got the Job, Details Will Follow.
Excerpt from Making the ‘Right’ Choice -
You have the idea, you...more
Certain payment models created under the Patient Protection and Affordable Care Act intended to coordinate care and lower healthcare costs raise questions concerning the tax-exempt status of debt issued by certain healthcare...more
Most issuers of healthcare insurance likely have heard about the $500,000 limit on deductible compensation that became effective January 1, 2013, but might be surprised to know how much broader the scope of the deduction is...more
The deadline for Assembly bills to be passed by the California State Assembly and for Senate bills to be passed by the California State Senate was last Friday, May 31. ...more
On April 5, the Treasury Department released proposed regulations that provide guidance on the community health needs assessment (“CHNA”) and other requirements for tax-exempt hospitals under section 501(r) of the Internal...more
A. Overview -
The investment diversification rules are a critical element in planning for private placement insurance products. One of the underlying marketing premises for the attractiveness of private placement...more
Part I and Part II have focused on the tax planning possibilities of small business owners and owners of professional corporations utilizing an exemption for collectively bargained plans. This exemption allows...more
Charitable organizations from hospitals to universities have a difficult time attracting and retaining top executive talent from the world of public corporations. Public corporations provide competitive...more
In This Edition:
- Year-end Deadline for Correcting Section 409A Deferred Compensation Arrangements That Condition Payment on an Employee Release or Covenant:
By December 31, 2012, all deferred compensation...more
Ready, set, go! Following the Presidential election last night, the race is on for year-end tax planning and bracing for the fall off the fiscal cliff.
While no one can tell exactly what the tax outcome will be after...more
Corporate owned life insurance assets (COLI) and Bank owned life insurance (BOLI) assets may account for close to $1 trillion or more of life insurance company assets. Virtually every major public corporation uses COLI. Why?...more
Part I of this article addressed the potential benefits of private placement variable annuities (PPVA) for wealthy non-resident alien taxpayers. Generally, tax treaties make all of this possible. As a result, annuities are...more
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