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HTMLTransfer Pricing Audits: Flipping the Tested Party
J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, Patricia Gimbel Lewis, H. David Rosenbloom; Caplin & Drysdale, Chartered;
Legal Alert/Article
August 14, 2015, previously published on August 13, 2015
In some recent transfer pricing audits, the Internal Revenue Service (IRS) "flipped the tested party" after examining transactions between related U.S. and foreign companies. Typically, this practice results in the attribution of a larger portion of profit from the relevant business...

 

HTMLNew Law Changes FBAR Filing Deadline
Mark D. Allison, Niles A. Elber, Charles M. Ruchelman, T. Joshua Wu, Zhanna A. Ziering; Caplin & Drysdale, Chartered;
Legal Alert/Article
August 10, 2015, previously published on August 10, 2015
Beginning with the FBAR (FinCEN Report 114) for the 2016 year, the filing deadline for the FBAR will be April 15th with a six-month extension until October 15th available upon request. The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, which was enacted on July 31,...

 

HTMLIRS Releases Guidelines for Examining CFC Transactions
J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, Patricia Gimbel Lewis, H. David Rosenbloom; Caplin & Drysdale, Chartered;
Legal Alert/Article
August 6, 2015, previously published on July 29, 2015
On July 17, 2015, the Internal Revenue Service (IRS) released three new "practice units," each examining a particular type of transaction involving a controlled foreign corporation (CFC). The IRS develops practice units internally for use both as training materials and as job aids for...

 

HTML"Steering" the Cadillac Tax II: An Additional Opportunity for Employers and Other Stakeholders
Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
August 5, 2015, previously published on August 5, 2015
Our March 2015 client alert "‘Steering' the Cadillac Tax: An Opportunity for Employers and Other Stakeholders" addressed IRS Notice 2015-16, which was an initial request for comments regarding the excise tax on high-cost, employer-sponsored health coverage (commonly referred to as...

 

HTMLTreasury Proposes Significant Changes to U.S. Model Tax Treaty
J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, Patricia Gimbel Lewis, H. David Rosenbloom; Caplin & Drysdale, Chartered;
Legal Alert/Article
July 3, 2015, previously published on May 26, 2015
On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model). The changes represent part of an extensive and ongoing overhaul of this document, which was last updated in 2006. According to Treasury officials, the proposed revisions are...

 

HTMLSupreme Court Ruling on Same-Sex Marriage Impacts Employee Benefit Plan Administration
Ronald G. Cluett, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
July 1, 2015, previously published on July 1, 2015
As most readers will already be aware, the Supreme Court's recent ruling in Obergefell mandates that same-sex marriage must now be licensed and recognized at the state level. While the ruling is unambiguous that the right to same-sex marriage is protected under the Fourteenth Amendment, future...

 

HTMLInvestment Advice and ERISA Fiduciary Responsibility
Ronald G. Cluett, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
May 29, 2015, previously published on May 26, 2015
Last month, the Department of Labor ("DOL") published new proposed regulations (the "Proposed Rules") addressing who is a fiduciary of an employee benefit plan by virtue of rendering investment advice to the plan or its participants.[1] As the specific details of the Proposed...

 

HTMLTreasury Proposes Significant Changes to U.S. Model Tax Treaty
J. Clark Armitage, Peter A. Barnes, Neal M. Kochman, Patricia Gimbel Lewis, H. David Rosenbloom; Caplin & Drysdale, Chartered;
Legal Alert/Article
May 28, 2015, previously published on May 26, 2015
On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model). The changes represent part of an extensive and ongoing overhaul of this document, which was last updated in 2006. According to Treasury officials, the proposed revisions are...

 

HTMLMaryland Taxpayers Win Income Tax Case in Supreme Court
William D. Fournier, Beth Shapiro Kaufman; Caplin & Drysdale, Chartered;
Legal Alert/Article
May 25, 2015, previously published on May 20, 2015
The U.S. Supreme Court ruled in favor of Maryland taxpayers on an income tax issue in Comptroller of the Treasury of Maryland v. Wynne, decided on May 18, 2015. Maryland residents file a single tax return that collects both the Maryland state income tax and any income taxes imposed by the county or...

 

HTML"Steering" the Cadillac Tax: An Opportunity for Employers and Other Stakeholders
Ronald G. Cluett, Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 24, 2015, previously published on March 4, 2015
The excise tax on high-cost, employer-sponsored health coverage (commonly referred to as the "Cadillac Tax") first received considerable attention when the Patient Protection and Affordable Care Act was enacted in 2010. The Cadillac Tax is effective for taxable years beginning after...

 


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