Legal Articles: Caplin & Drysdale, Chartered

 







Document(s) published by this organization: 28


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HTMLIRS 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;
Legal Alert/Article
April 11, 2014, previously published on April 10, 2014
On 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...

 

HTMLU.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;
Legal Alert/Article
April 10, 2014, previously published on April 2, 2014
The 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,...

 

HTMLIRS Modifies Program for Pre-Approval of 403(b) Plan Documents
Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
April 10, 2014, previously published on April 8, 2014
Our 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...

 

HTMLRemain Vigilant on Indian Permanent Establishments, Even After the Favorable e-Funds Decision
J. Clark Armitage, Peter A. Barnes, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
Legal Alert/Article
April 1, 2014, previously published on March 27, 2014
The 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...

 

HTMLFinal IRS Regulations on Information Reporting Under PPACA
Brady McDaniel, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 26, 2014, previously published on March 24, 2014
On March 10, 2014, the IRS published final Treasury regulations for two separate information reporting requirements added to the Internal Revenue Code by the Patient Protection and Affordable Care Act of 2010, as amended ("PPACA"). Both require certain employers to file information...

 

HTMLCommon Sense Prevails - NY High Court Clarifies Tax Residency Test
Peter A. Lowy; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 19, 2014, previously published on March 13, 2014
Isn't it common sense that in order to be a "resident" of a State one must actually reside in the State? Not so for the State of New York's taxing authority.

 

HTMLBold Shift in IRS Approach to Transfer Pricing Controversies
J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, Patricia Gimbel Lewis; Caplin & Drysdale, Chartered;
Legal Alert/Article
February 27, 2014, previously published on February 27, 2014
U.S. taxpayers should prepare for major changes in IRS transfer pricing audits. New procedures, sharpened objectives, accelerated taxpayer decision points, and revised resolution opportunities will result from a confluence of just-issued IRS guidance. All will require refined handling of audits...

 

HTMLFinal IRS Regulations on Employer Shared Responsibility
Brady McDaniel, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
February 19, 2014, previously published on February 12, 2014
On February 10, 2014, the IRS issued final regulations on the employer shared responsibility provisions of the Patient Protection and Affordable Care Act of 2010, as amended ("PPACA"). The regulations are applicable for periods after December 31, 2014. The preamble to the regulations...

 

HTMLIRS Has Eliminated "Expedited Handling" Option for Exempt Organizations Seeking Determination Letters
Caplin Drysdale Chartered;
Legal Alert/Article
January 7, 2014, previously published on January 3, 2014
On January 2, 2014, the Internal Revenue Service released Revenue Procedure 2014-4, updating the agency's procedures for processing ruling requests and determinations relevant to tax-exempt organizations. One significant update could affect many exempt organizations that have ruling requests...

 

HTML2014 Estate Planning: Should I Take Advantage of Portability?
Beth Shapiro Kaufman, Anne J. O'Brien; Caplin & Drysdale, Chartered;
Legal Alert/Article
January 2, 2014, previously published on December 23, 2013
As part of the American Taxpayer Relief Act of 2012, Congress made permanent the portability of estate tax exemption between spouses. Although this change was supposed to be a simplification for married couples, after a year of experience with it, we have concluded that it is anything but simple!

 


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