On August 15, 2024, the Internal Revenue Service (IRS) launched a second Employee Retention Credit (ERC) Voluntary Disclosure Program for employers to correct any mistakes related to their ERC claims. The ERC, introduced by...more
We are often asked if one has to pay taxes when selling goods or services online. That question became even more relevant this week when the IRS postponed the new “$600 Rule.” This is a particular relief for those wo receive...more
On October 17, 52 state and territorial attorneys general, in addition to state money transmission regulators, entered into settlements amounting to more than $20 million with ACI Worldwide (ACI), to resolve claims involving...more
On 22 September 2022, the Financial Conduct Authority (FCA) published its consultation paper (CP 22/18, the CP) which proposes new guidance on the trading venue perimeter. The CP follows on from the discussion on this as part...more
As we wrote in December, third-party payment networks, such as PayPal and Venmo, must report to the IRS any transactions for goods or services in excess of $600 starting this year. The House’s Build Back Better Proposal would...more
Small businesses take note: Starting January 1, third-party payment networks, such as PayPal and Venmo, must report to the IRS any transactions for goods or services in excess of $600. Under current law, such “third party...more
On February 5, 2021, the acting head of the U.S. Department of Justice (“DOJ”) division that brings environmental enforcement cases issued a memo revoking nine policy directives from the prior administration, including...more
Anyone who interacts with third party payors encounter acronyms on a regular basis. While acronyms are intended to facilitate efficient communication, their use often instead leads to confusion. This blog is intended to...more
On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more
It is one thing to wake up and find yourself as the lead story on a Sunday morning when the New York Times (NYT) runs a corruption story about your organization above the fold. It is quite another when the world’s top...more
California has joined the growing ranks of states, as well as the federal government, in efforts to facilitate the efficient provision of healthcare services during the pandemic....more
Germany has notoriously broad voidability laws. As a rule of thumb, any payment by a third party has high voidability risks if the third party has no obligation to make the payment under the contract....more
China is marching on to be the world's pioneering cashless society but unfortunately there is an almost complete absence of foreign counterparts in the huge Chinese domestic or cross border transactions initiated from China. ...more
Three cases recently wrapped up in the Northern and Southern Districts of Texas reveal an increased focus on health care fraud committed against private commercial third-party payors, as well as the tools that the Department...more
In a memorandum dated June 5 and entitled “Prohibition on Settlement Payments to Third Parties,” the United States Department of Justice (DOJ) announced an important new policy that will likely limit the ability of settling...more
One of the most talked about topics when it comes to digital health is the reimbursement under various third-party payer programs. Most notably, telemedicine and remote monitoring have received a lot of attention, and the...more
Effective August 1, 2016, new Nasdaq Rule 5250(b)(3) requires Nasdaq-listed companies to disclose the material terms of all agreements and arrangements between a director or director nominee and a third party related to...more
On July 1, 2016, the Securities and Exchange Commission (the “SEC”) approved, on an accelerated basis, proposed amendments to the listing rules of The Nasdaq Stock Market LLC (“Nasdaq”) to require Nasdaq-listed companies to...more
A new requirement that Nasdaq-listed companies disclose certain payments made to directors by third parties is scheduled to go into effect on August 1, 2016. The new rule targets so-called “golden leash” payments made to...more