Investment Management Legal + Regulatory Update: February 2012 by Morrison & Foerster LLP on 2/10/2012 In this issue: Senate Bill Would Raise Taxes on Derivatives Trades; Senate Hearings Question Fund Investments in Commodity-related Investments; SEC Grants No-action Relief for Potential Section 10(f) Violations; FINRA...more
Supreme Court to Hear Appeal on Constitutionality of Health Reform Law by Sutherland Asbill & Brennan LLP on 11/22/2011 On Monday, November 14, the U.S. Supreme Court granted certiorari to hear an appeal from a decision by the U.S. Court of Appeals for the Eleventh Circuit that the individual mandate in the Patient Protection and Affordable...more
Another Federal Court of Appeals Weighs in on the Applicability of the Six-Year Statute of Limitations Period to an Overstatement... by McDermott Will & Emery on 8/8/2011 The U.S. Court of Appeals for the D.C. Circuit recently reversed two U.S. Tax Court decisions and held that an overstatement of basis constitutes an omission from gross income that is subject to the six-year statute of...more
Congress Defaults on Job Creation by SEO | Law Firm on 7/14/2011 By Kristen Friend, staff U.S. Supreme Court and Congress writer – July 14, 2011 Challenges continue to mount for lawmakers on Capitol Hill, with a bleak June jobs report adding heat to ongoing arguments over budget...more
Federal tax benefit rule applies under Michigan law by Warner Norcross & Judd on 5/23/2011 In Sturrus v. Department of Treasury, No. 295403, the Michigan Court of Appeals held that Michigan’s Income Tax Act (ITA) incorporates the federal tax benefit rule, 26 U.S.C. 111(a), but the rule did not apply to the...more
German Tax Law: Estate Tax, Inheritance Tax, and Gift Tax in Germany by Holger Siegwart on 3/21/2011 Information on estate tax and inheritance tax in Germany. Calculate your tax liability if you inherit money or property in Germany. Easy to follow explanation in English from a German lawyer in the United States....more
Probate and Inheritance in Germany by Holger Siegwart on 3/20/2011 Introduction to German probate and inheritance law from an attorney licensed in Germany and the US (California)....more
Analysis: Federal Court Suspends Colorado Use Tax Reporting Requirements; Neutral Forum Reinvigorates Quill by McDermott Will & Emery on 2/2/2011 A federal district court recently granted a motion for preliminary injunction filed by The Direct Marketing Association, thereby enjoining the Colorado Department of Revenue from enforcing its sales and use tax notification...more
Appeals Court Breathes New Life Into Overstated Basis Issue by Charles (Chuck) Rubin on 1/29/2011 On several occasions, we have written about cases where courts have held that the six-year extended statute of limitations for a 25% omission of gross income from an income tax return will not apply when the unreported...more
United States v. UBS AG, Amended Protocol Between the U.S. and Switzerland (Amending August 2009 Agreement) by Santiago Cueto on 3/31/2010 Switzerland and the US Wednesday 31 March both signed an “amending protocol” to their 19 August 2009 agreement whereby the Swiss promised to issue final decisions on some 4,450 UBS bank clients whose account information was...more
Ninth Circuit Reverses Tax Court on Including Stock Option Costs in Cost-Sharing Agreement: A Tale of Two Regulations by Morrison & Foerster LLP on 6/3/2009 On May 27, in a 2-1 panel decision, the Ninth Circuit Court of Appeals reversed the United States Tax Court in Xilinx, Inc. v. Commissioner and remanded on two specific issues. The Ninth Circuit held that, under Treasury...more
United States v. UBS AG, U.S. - Switzerland Protocol Amending Treaty for the Avoidance Double Taxation by Santiago Cueto on 2/19/2009 August 2009 agreement whereby Switzerland promised to issue final decisions on some 4,450 UBS bank clients whose account information was requested by US tax authorities. An Amended Protocol was signed on March 31, 2010....more
CONSTITUTIONAL VALIDITY of U.P. Sheera Niyanthran Adhiniyam, 1964. by MANOJ SASIDHARAN on 10/9/2008 The study attempts to examine the constitutional validity of enactments made by State legislatures in respect of raw materials used by industries involved in manufacture of Alcoholic products, with particular reference to the...more