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Principal Purpose Test

Jenner & Block

Supreme Court Evaluates Scope of Attorney-Client Privilege for Dual-Purpose Communications

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On January 9, 2023, the US Supreme Court heard oral argument in the matter of In re Grand Jury, No. 21-1397, which asked the Court to determine whether “dual-purpose” communications involving both legal and business advice...more

Bailey & Glasser, LLP

“Improvidently Granted”: Supremes Decline to Wade Into Attorney-Client Privilege Dispute

Bailey & Glasser, LLP on

Recently, we wrote a blog post about the Supreme Court entertaining arguments on the scope of the attorney-client privilege in the context of dual-purpose communications paraphrasing a question from Justice Kagan during the...more

Jackson Lewis P.C.

U.S. Supreme Court Dismisses as ‘Improvidently Granted’ Case on Scope of Attorney-Client Privilege

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In a per curiam opinion, the U.S. Supreme Court has dismissed the writ of certiorari granted in In re: Grand Jury, No. 21-1397, writing only that it was “improvidently granted.” The Court can dismiss any granted writ of...more

Smith Debnam Narron Drake Saintsing & Myers,...

Sixth Circuit Examines Who is a Debt Collector for Purposes of FDCPA Section 1692(f)(6)

The Sixth Circuit Court of Appeals recently explored the limitations of Section 1692(f)(6) and held that a property preservation and maintenance company was not a debt collector for purposes of that section. The opinion...more

Bennett Jones LLP

Federal Court of Appeal Upholds Treaty-Based Canadian Holding Structure

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On February 12, 2020, the Federal Court of Appeal (FCA) in Canada v Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 [Alta Lux] concluded that the Canada-Luxembourg tax treaty (Can-Lux Treaty) was not abused when a Luxembourg...more

Bennett Jones LLP

Tax Treaty Benefits Threatened as Canada Completes Ratification of OECD's Multilateral Instrument

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On August 29, 2019, Canada completed its domestic ratification of the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI). As noted in our...more

Bennett Jones LLP

New Ratifications of the OECD's Multilateral Instrument Put Canadian Resource Holding Structures at Risk

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Tax-efficient holding structures commonly used by multinational enterprises and private equity firms investing in the Canadian resource sector could soon become subject to anti-treaty shopping measures contained in the...more

Ballard Spahr LLP

Passive Debt Buyers Beware: Third Circuit Broadens FDCPA Liability Under the 'Principal Purpose' Definition

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Persons or entities that engage third parties to collect consumer debts they acquired when the debts were in default, known as "passive debt buyers," are "debt collectors" subject to the Fair Debt Collection Practices Act...more

White & Case LLP

Belgian draft law ratifying the MLI: A new paradigm in international tax law

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On February 4th, 2019, the Belgian government released a draft law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the "Convention") and the...more

Bradley Arant Boult Cummings LLP

First Party Creditors Should Carefully Consider the Upcoming Debt Collection Rules

On October 17, 2018, the Bureau of Consumer Financial Protection (BCFP), formerly known as the CFPB, announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA)...more

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