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Read need-to-know updates, commentary, and analysis on Tax issues written by leading professionals.

Tax Reform Passes The Next Hurdle -- The Senate

by Seyfarth Shaw LLP on

This is the second issue in a planned series of alerts for employers on selected topics on tax reform. The series of Tax Reform Management Alerts is designed to provide an in-depth analysis of executive compensation and...more

SLGS Window Closing; Tax Reform Continues to Threaten Public Finance

by Bracewell LLP on

On December 6, 2017, the U.S. Department of the Treasury announced the suspension of sales of United States Treasury Obligations – State and Local Government Series (i.e., SLGS), effective 12:00 noon Eastern Time, Friday,...more

Recent Developments in Transfer Pricing and the Taxation of Multinational Companies in Australia

by Jones Day on

As part of a wide-ranging crackdown on multinational tax avoidance, the Australian Federal Government and the Australian Tax Office have introduced significant reforms to the country’s transfer pricing regulations. The...more

U.S. Court Orders Coinbase to Share Information about Account Holders with the IRS but Limits to Transactions over $20,000

A U.S. federal district court judge on Tuesday, November 29 ordered Coinbase Inc., the largest cryptocurrency exchange and storage platform in the world, to provide information about certain of its account holders to the U.S....more

Paradise Papers: The Latest Offshore Leak

by Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Asset Management Regulatory Roundup - November 2017 - Issue 11

by Dechert LLP on

A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more

What would happen to the value of cryptocurrencies if Exchanges had to Issue a Form 1099 on an annual basis?

by Sanford Millar on

The IRS issued a John DOE Summons for records of U.S. account holders of Coinbase, Inc. (“Coinbase”) a cryptocurrency exchange based in San Francisco, California. Coinbase objected to production of the records and a Summons...more

Orrick's Financial Industry Week In Review

CFTC’s Division of Market Oversight Extends Time-Limited No-Action Relief for SEFs from Certain Block Trade Requirements - On November 14, 2017, the U.S. Commodity Futures Trading Commission's Division ("CFTC") of Market...more

French Legal and Regulatory Update – October 2017

by Hogan Lovells on

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e-newsletter, which offers a legal and regulatory update covering France and Europe for October 2017. Please see full...more

What If You Are Ineligible For The Offshore Voluntary Disclosure Program? Attorney Proffers versus Quiet Disclosures

by Sanford Millar on

Since the beginning of the current Offshore Voluntary Disclosure Programs (OVDP) in 2009 tens of thousands of U.S. taxpayers have come forward to report previously undisclosed foreign financial accounts. The addition of the...more

Executive Regulation on Value Added Tax in the UAE

by Bracewell LLP on

The United Arab Emirates (“UAE”) Federal Tax Authority has recently published the draft Executive Regulations of Federal Decree Law No. 8 of 2017 on Value Added Tax (the “VAT Law”) which introduces a 5% VAT on the import and...more

California Card Club Plagued By Allegations Of Criminal Activity Fined $8 Million For AML Violations

by Fox Rothschild LLP on

Today the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it had fined a California card club, Artichoke Joe’s Casino, $8 million for numerous willful violations of the Bank Secrecy Act...more

Sixth Circuit Not Willing to Relent that Business Owner Was Liable for Trust Fund Tax Penalty Despite Creditor's Control over...

by Baker Donelson on

In Robert Karban, Jr. v. United States of America, earlier this year, the Sixth Circuit ruled that Mr. Karban, the owner of a manufacturing company, was a responsible person for paying over trust fund taxes, which he...more

International Tax Issues Are A Major Focus of Newest Launch of IRS Compliance Campaigns in 2017

by M. Robinson & Company, P.C. on

Earlier this year, the IRS Large Business and International division (LB&I) rolled out 13 compliance campaigns to target both individual taxpayers and corporations for examinations on certain tax compliance issues. On...more

Tax Planning Under the Tax Cuts and Jobs Act: Flow-Throughs Are the Answer to Everything

by Proskauer - Tax Talks on

The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more

The Impact on Financing Transactions if the House’s “Tax Cuts and Jobs Act” Passes

On November 2, 2017, House Ways and Means Committee Chairman Kevin Brady (R-TX) introduced a tax bill entitled the Tax Cuts and Jobs Act (“H.R. 1”), and later proposed amendments to the bill on November 3, November 6, and...more

Effects of House Tax Reform Bill on Securitizations and Funds

On November 2, 2017, Republicans in the House of Representatives released their long-anticipated tax reform bill (the “Bill”). The Bill, which is entitled the “Tax Cuts and Jobs Act,” includes significant changes to the...more

Tax Reform Bill Proposes to Eliminate UBTI Exemption for Government Plans

by Morgan Lewis on

House bill, if enacted, will alter tax analysis with respect to fund investments. On November 2, House Republicans released their draft tax reform bill. Of particular interest to government pension plans is a provision...more

Federal Tax Reform: House Bill Rewrites Municipal Bond Rules

by Ballard Spahr LLP on

The proposed Tax Cuts and Jobs Act released last week would eliminate the federal tax exemption for interest earned on all private activity bonds—including 501(c)(3) bonds and exempt facility bonds—and advance refunding bonds...more

Summary of State and Local Government Bond Provisions in the Tax Cuts and Jobs Act

On November 2, 2017, the Republican leadership of the United States House of Representatives introduced the Tax Cuts and Jobs Act (the “Bill”). The Bill would make significant changes to tax rules that apply to tax-exempt...more

House Tax Bill Eliminates Private Activity Bonds, Advance Refundings

by Sherman & Howard L.L.C. on

The House Ways and Means Committee released on November 2, 2017, its draft tax bill (the “Tax Cuts and Jobs Act”), which contains provisions restricting the ability of state and local governments to issue certain types of...more

Colorado Court of Appeals Rules Out-of-State Holding Company Cannot Be Forcibly Included in a Colorado Combined Return

by Morrison & Foerster LLP on

The Colorado Court of Appeals, affirming a decision of the Denver District Court, has held that the Colorado Department of Revenue cannot forcibly combine a corporation’s subsidiary, a holding company that derived its income...more

Seed Investment Structures for Startups: the SAFE (Simple Agreement for Future Equity)

Convertible notes are popular financing instruments for structuring seed-stage investments because they offer a simple, cost effective means of documenting seed capital investments. The “Simple Agreement for Future Equity”...more

Money Laundering Watchdog Criticizes Lax AML Enforcement and “Creative Compliance” in Wake of Panama Papers

by Ballard Spahr LLP on

PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more

Pennsylvania Supreme Court Declares Dollar-Based NOL Cap Unconstitutional

by Ballard Spahr LLP on

In a unanimous decision in Nextel Communications of the Mid-Atlantic, Inc. v. Commonwealth, the Pennsylvania Supreme Court affirmed the Commonwealth Court's holding that Pennsylvania's dollar-based cap on corporate net income...more

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