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Private Ruling Endorses Taxpayer-Friendly Reading of “Qualified Small Business” Under Section 1202

On September 5, 2014, the Internal Revenue Service (“IRS”) released Private Letter Ruling 201436001 (the “Ruling”), which found that a company providing products and services primarily within the pharmaceutical industry was a...more

Capital Thinking: Health Care

LEGISLATIVE ACTIVITY - On Monday, July 28, the House Committee on Energy and Commerce, Subcommittee on Health will hold a markup to consider two bills: H.R. ____, a bill to require the Secretary of Health and Human...more

Delhi High Court upholds Centrica ruling: employee secondment may trigger permanent establishment

Multinationals with operations in India should take note of the Delhi High Court’s recently decision in Centrica India Offshore Pvt Ltd., in which it upheld a ruling of the Authority for Advance Rulings that an employee...more

Tax Consequences of Telecommuting Employees

Technology companies have been at the forefront of accommodating telecommuting employees who wish to work from home for lifestyle and other reasons. Companies may want to re-think this employee policy because of the...more

IRS Issues Significant Convertible Virtual Currency Ruling – Bitcoin Community Abuzz

The IRS has issued its first major ruling on the U.S. federal tax implications of transactions in, or transactions that use, Bitcoin and other convertible virtual currencies. The ruling stresses that it relates to convertible...more

The Boricua Option – The Taxation of Incentive Stock Options (ISOs) as a Puerto Rican Resident - Another Good Reason to Move to La...

Overview - Many professional living and working in Silicon Valley over the last twenty years have become very wealthy as a result of their participation in company stock options plans – qualified and non-qualified....more

Take 5 Newsletter: Five Hot Topics for Financial Services Industry Employers

The economy may be improving, but challenges remain for employers in the financial services industry. From ever-increasing whistleblower claims to new diversity and inclusion regulations and recent IRS determinations...more

U.S. Supreme Court Update - January 2014

Court Begins 2013-2014 Term - Upon starting its 2013-2014 term during the government's recent partial shut-down, the U.S. Supreme Court opened with a grant of certiorari in a case with state and local tax implications,...more

Software Vendor Challenges Massachusetts’ Restrictive Policy on Multiple Points of Use Certificates

Software purchasers that have paid Massachusetts sales tax on the full purchase price for software that was also concurrently available for use by employees outside Massachusetts, should consider filing protective refund...more

Higher Education Highlights - Spring 2013

In This Issue: - U.S. Supreme Court to Rule on Causation Factor in Retaliation Claims - Student Sues University Over the Right to Keep a Guinea Pig in a College Dorm for Emotional Support - Delaware...more

China 20/20: Legal & Regulatory Developments

In This Issue MOFCOM Issues Measures on Investigation and Handling of Failure on Declaration of Business Operators' Concentration Implementing Regulations for the PRC Bid Invitation and Submission Law Tax...more

2011 in Review: ERISA Individual Prohibited Transaction Exemptions

In 2011, the Department of Labor (DOL) continued a fairly active program of issuing individual exemptions from the prohibited transaction rules of ERISA. These rules generally prohibit, among other things: -Sale and...more

2010 in Review: ERISA Individual Prohibited Transaction Exemptions

In 2010, the Department of Labor (DOL) continued an active program of issuing individual exemptions from the prohibited transaction rules of ERISA. These rules generally prohibit, among other things: Sale and lending...more

Treasury Department Issues Guidance On Therapeutic Discovery Project Tax Credit And Grant Program For Small Employers

The recent Patient Protection and Affordable Care Act, Pub. L. No. 111-148 (PPACA), established a limited-time federal tax credit and grant program for certain investments incurred in 2009 and 2010 by small employers for...more

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