Document(s) published by this organization: 24
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|Letter to DOJ Confirms IRS Intent to Resume Church Tax Inquiries
Michael W. Durham, Diara M. Holmes, William M. Klimon, Marcus S. Owens, Douglas N. Varley; Caplin & Drysdale, Chartered;
August 11, 2014, previously published on August 7, 2014In a June 27, 2014 letter to the Department of Justice, the Acting Director of IRS Exempt Organizations Examinations revealed three potentially significant developments with respect to IRS enforcement activity against churches.
|IRS Issues Final Regulations on Material Advisor Penalties|
Mark D. Allison, Rachel Leigh Partain, Christopher S. Rizek, Zhanna A. Ziering; Caplin & Drysdale, Chartered;
August 4, 2014, previously published on August 4, 2014On July 30, 2014, the Internal Revenue Service issued final regulations regarding the imposition of penalties under Internal Revenue Code section 6707 against material advisors who fail to file true, complete or timely disclosure returns with respect to reportable or listed transactions. The...
|IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures|
Scott D. Michel, Zhanna A. Ziering; Caplin & Drysdale, Chartered;
July 9, 2014, previously published on June 23, 2014On June 18, 2014, the IRS unveiled significant changes to both Offshore Voluntary Disclosure Program (OVDP) and Streamlined Filing Compliance Procedures (SFCP). The changes both relax the penalty structure for non-willful behavior but increase it soon for account holders at certain banks. The...
|SEC Issues "Pay-to-Play" Penalty to Investment Adviser|
Kirk L. Jowers, Trevor Potter, Matthew T. Sanderson; Caplin & Drysdale, Chartered;
July 9, 2014, previously published on June 26, 2014Private equity firm TL Ventures Inc. agreed last week to settle Securities and Exchange Commission ("SEC") charges that it violated "pay-to-play" rules, in what the agency said was the first pay-to-play case against an investment adviser. TL Ventures, as part of the settlement,...
|Recent IRS Activity Focuses on Nonqualified Deferred Compensation Plans|
Joanne C. Youn; Caplin & Drysdale, Chartered;
July 9, 2014, previously published on July 7, 2014Recent IRS efforts have provoked renewed discussion of the legal regimes governing nonqualified deferred compensation plans. First, the IRS announced a small-scope audit project addressing Code section 409A ("409A"). Second, the IRS released Revenue Ruling 2014-18 addressing Code section...
|Maryland Estate Tax Exemption Set to Rise|
William D. Fournier, Beth Shapiro Kaufman, Anne J. O'Brien, Megan E. Wernke; Caplin & Drysdale, Chartered;
June 3, 2014, previously published on May 16, 2014On May 15, 2014, Governor O'Malley signed into law new legislation that will gradually increase the Maryland estate tax exemption from the current $1 million to match the indexed federal exemption in 2019. This means that Maryland's estate tax exemption will now be increasing annually. These...
|IRS Issues Important Guidance for Employers on Application of U.S. v. Windsor to Qualified Retirement Plans|
Ronald G. Cluett, Joanne C. Youn; Caplin & Drysdale, Chartered;
April 11, 2014, previously published on April 10, 2014On June 26, 2013, the Supreme Court in United States v. Windsor declared unconstitutional Section 3 of the Defense of Marriage Act ("DOMA") which defined marriage for purposes of federal law as marriage between a man and a woman. The IRS has subsequently issued guidance on the application...
|U.S. Supreme Court Releases Opinion in McCutcheon v. Federal Election Commission|
Joseph M. Birkenstock, Kirk L. Jowers, Trevor Potter, Matthew T. Sanderson; Caplin & Drysdale, Chartered;
April 10, 2014, previously published on April 2, 2014The U.S. Supreme Court released its long-anticipated opinion in McCutcheon v. Federal Election Commission this morning. Through a 5-4 decision, McCutcheon strikes down aggregate caps in federal campaign finance law that have limited an individual's total contributions to all federal candidates,...
|IRS Modifies Program for Pre-Approval of 403(b) Plan Documents|
Joanne C. Youn; Caplin & Drysdale, Chartered;
April 10, 2014, previously published on April 8, 2014Our April 2013 client alert IRS Finalizes Program for Pre-Approval of 403(b) Plan Documents discussed the establishment of the IRS program for pre-approval of prototype and volume submitter 403(b) plan documents which was first announced in 2009 (the "Program"). This client alert updates...
|Remain Vigilant on Indian Permanent Establishments, Even After the Favorable e-Funds Decision|
J. Clark Armitage, Peter A. Barnes, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
April 1, 2014, previously published on March 27, 2014The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases. Some of the important issues involved are: the appropriate markup on costs for services; when and how to reward location savings; and whether marketing...