On February 15, 2019, the Internal Revenue Service (the “IRS”) released PLR 201907001 (the “Ruling”), a private letter ruling addressing whether certain income related to the leasing of an oil and gas platform, selling of...more
5/3/2019
/ Capital Assets ,
Corporate Counsel ,
Equipment Lease ,
Internal Revenue Code (IRC) ,
IRS ,
Oil & Gas ,
Pipelines ,
Private Letter Rulings ,
REIT ,
Rental Income ,
Storage Tanks
On October 19, 2018, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under new section 1400Z-2 of the Internal Revenue Code (the “Code”),...more
On September 13, 2018, the Internal Revenue Service (the “Service”) released Revenue Procedure 2018-48 (the “Revenue Procedure”), which provides guidance on how certain items of foreign-related income are treated for purposes...more
On May 7, 2018, House Bill 696 was signed into law by Georgia Governor Nathan Deal. The new law exempts qualifying high-technology data centers from Georgia sales and use taxes. With Georgia sales and use tax rates ranging...more
The new Tax Cuts and Jobs Act has changed certain provisions of the Internal Revenue Code (the Code) pertaining to the deductibility of amounts paid to Government entities for violations of law. Section 162(a) of the Code has...more
On September 29, 2017, the United States District Court for the Western District of Texas struck down a 2016 temporary regulation designed to limit corporate inversions(the “Rule”). Rule was simultaneously issued as a...more
On July 26, 2017, the Tax Court issued its opinion in Eaton Corp. v. Commissioner, holding that the IRS’s cancellation of two advance pricing agreements (“APAs”) reached with Eaton Corporation (“Eaton”) was “arbitrary and...more
In the week since the Supreme Court’s unanimous decision in Kokesh v. SEC, which rejected the Securities and Exchange Commission’s longstanding position that disgorgement was an equitable remedy not subject to the five-year...more
6/14/2017
/ Disgorgement ,
Enforcement Actions ,
Financial Services Industry ,
Investment Management ,
Kokesh v SEC ,
Misappropriation ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Statute of Limitations ,
White Collar Crimes