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HTMLThe Panama Papers and the U.S. Response: New Risks for Financial Institutions, Clients and Advisors
Mark E. Matthews, Scott D. Michel, Cono R. Namorato; Caplin & Drysdale, Chartered;
Legal Alert/Article
May 18, 2016, previously published on May 18, 2016
The massive Panama Papers leak from the law firm Mossack Fonseca has exposed a variety of suspicious and possibly illegal activity and drawn the attention of tax enforcement authorities and investigators worldwide. On May 9, 2016, the International Consortium of Investigative Journalists (ICIJ),...

 

HTMLProducts Liability Plaintiffs Prevented From Seeking Recovery Against New GM Because the Bankruptcy Court Found Their Claims Were Not Assumed by New GM
Jeanna Rickards Koski, Todd E. Phillips; Caplin & Drysdale, Chartered;
Legal Alert/Article
April 27, 2016, previously published on April 25, 2016
On April 15, 2016, the Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”) halted the attempt of plaintiffs who were injured in an accident involving a General Motors vehicle to seek recourse against General Motors LLC (“New GM”) in state court,...

 

HTMLTreasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership
J. Clark Armitage, Kirsten Burmester, Scott D. Michel, Michael G. Pfeifer, H. David Rosenbloom; Caplin & Drysdale, Chartered;
Legal Alert/Article
April 26, 2016, previously published on April 5, 2016
In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners. Penalties could be significant for continued non-compliance, and...

 

HTMLThe New Fiduciary Rules: Considerations for Employers
Joanne C. Youn; Caplin & Drysdale, Chartered;
Legal Alert/Article
April 13, 2016, previously published on April 12, 2016
Last week, the Department of Labor ("DOL") published final regulations (the "Final Rules") addressing who is a fiduciary of an employee benefit plan or IRA by virtue of rendering investment advice to the plan, its participants, and/or the IRA owner. The potential impact of the...

 

HTMLCalifornia Limits "Ride-Along" Lobbying Exception to Employees who are Subject Matter Experts
Bryson B. Morgan, Trevor Potter, Matthew T. Sanderson; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 24, 2016, previously published on March 24, 2016
On March 17, 2016, the California Fair Political Practices Commission ("FPPC") amended its regulations to narrow the so-called "ride-along" exception. The exception is now available only to in-house employees who act as "subject matter experts" in communicating with...

 

HTMLIRS Seeks Comments to Promulgate Regulations for New Tax Examination and Collection Regime for Partnerships and LLCs
Charles M. Ruchelman; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 18, 2016, previously published on Match 18, 2016
Late last year, Congress completely overhauled the rules by which the Internal Revenue Service ("IRS") examines partnerships and limited liability companies ("LLC"). With the stroke of a pen, Congress repealed over three decades of the Tax Equity and Fiscal Responsibility Act of...

 

HTMLIRS/DOJ Summons Seeks to Break Singapore Bank Secrecy on Non-Resident's Account
Mark E. Matthews, Scott D. Michel; Caplin & Drysdale, Chartered;
Legal Alert/Article
March 7, 2016, previously published on Match 7, 2016
In late February 2016, the Justice Department filed an action in federal court to compel UBS's branch in Miami to produce bank records of a Singapore account purportedly owned by a taxpayer who lives in China and is under IRS audit. With a tactic not used in several years, this heralds the opening...

 

HTMLCalifornia Enhances Lobbying Disclosure Requirements for Lobbyist Employers and "$5,000 Filers"
Rachel E. Goldstein, Bryson B. Morgan, Trevor Potter, Matthew T. Sanderson; Caplin & Drysdale, Chartered;
Legal Alert/Article
February 2, 2016, previously published on January 25, 2016
The California Fair Political Practices Commission ("FPPC") by unanimous vote on January 21, 2016 revised its regulation governing the disclosure of lobbying expenditures by lobbyist employers and so-called "$5,000 filers." These more comprehensive disclosures will be required...

 

HTMLIs It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company 
J. Clark Armitage, Patricia Gimbel Lewis, Natalie Punchak; Caplin & Drysdale, Chartered;
Legal Alert/Article
January 7, 2016, previously published on December 23, 2015
On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to...

 

HTML2016 Federal and State Estate Gift Tax Exemptions for D.C., Maryland, and Virginia
William D. Fournier, Beth Shapiro Kaufman, Anne J. O'Brien, Megan E. Wernke; Caplin & Drysdale, Chartered;
Legal Alert/Article
December 29, 2015, previously published on December 28, 2015
Each year, certain estate, gift and generation-skipping transfer tax figures are subject to inflation adjustments. This client alert addresses inflation adjustments and other changes in federal and state estate and gift tax exemptions, that take effect January 1, 2016, for D.C., Maryland, and...

 


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