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Adobe PDFOnly the Lonely: “Lonely” Life Insurance Companies Confront New Issues Under Proposed Debt-Equity Regulations
Dennis L. Allen, Thomas A. Gick, Michael R. Miles, Mary E. Monahan, William R. Pauls; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 29, 2016, previously published on April 28, 2016
The rules of IRC § 1504 and Treas. Reg. § 1.1502-47 provide the general parameters for determining whether a domestic life insurance company (within the meaning of IRC § 816(a)) may join in filing a consolidated U.S. federal income tax return with one or more domestic nonlife...

 

HTMLBills, Bills, Bills: Texas Court of Appeals Scrubs Bill Pay Service Provider Free of Sales Taxes
Elizabeth S. Cha, Charles C. Kearns; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 28, 2016, previously published on April 27, 2016
In Hegar v. CheckFree Serv. Corp., a Texas Court of Appeals affirmed the trial court’s decision and held that the taxpayer’s online bill pay service was not a taxable data processing service for Texas sales tax purposes.

 

HTMLUPDATE: Federal Defend Trade Secrets Act Clears the House, Passage into Law Expected
Ann G. Fort, Matt Gatewood, Peter G. Pappas, William L. Warren, Gail L. Westover; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 28, 2016, previously published on April 28, 2016
As expected, overwhelming support for the Defend Trade Secrets Act of 2016 led to its passage in the U.S. House of Representatives yesterday by a 410-2 vote. During the floor debate, one Congressman noted that “Congress has the responsibility to give industries the tools they need to protect...

 

HTMLTexas Comptroller Issues "Strong" Decision, Companies' Single Shared Administrator Not Sufficient to Require Unitary Combined Filing
Evan M. Hamme, Marc A. Simonetti; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 28, 2016, previously published on April 28, 2016
The Texas Comptroller upheld a taxpayer’s separate Franchise Tax return filing position, rejecting an Administrative Law Judge’s finding that the taxpayer and its affiliate shared a strong centralized management structure that required a unitary combined report.

 

HTMLNorth Carolina Rejects Third-Party Sales of Solar-Generated Electricity
Tracey K. Ledbetter, James A. Orr; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 28, 2016, previously published on April 28, 2016
The North Carolina Utilities Commission recently ruled that third-party sales of solar-generated electricity violate state law. The Commission rejected a test case brought by an advocacy group seeking to legitimize such third-party sales.

 

HTMLDOE Denies Rehearing of Order Authorizing Dominion Cove Point LNG Exports
Sutherland Asbill Brennan LLP;
Legal Alert/Article
April 27, 2016, previously published on April 25, 2016
The U.S. Department of Energy (DOE) has issued an order denying Sierra Club’s request for rehearing of DOE’s order, which authorizes Dominion Cove Point LNG (DCP) to export 281 Bcf/year of LNG over a 20-year period from DCP’s proposed LNG export terminal at Lusby, Md. to nations...

 

HTMLState Tax Fallout From Federal Proposed Related-Party Debt Regulations
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 27, 2016, previously published on April 26, 2016
Recently proposed Treasury regulations under IRC § 385 (the Proposed Regulations) would create sweeping changes to the federal income tax treatment of related-party debt. The Proposed Regulations could also have far-reaching effects for state income tax purposes, particularly on the...

 

HTMLGAO Says DOT Should Do More To Combat Real-World Cyberattacks
Sutherland Asbill Brennan LLP;
Legal Alert/Article
April 27, 2016, previously published on April 27, 2016
In a recent report, the Government Accountability Office asserted that more needs to be done by the Department of Transportation and the National Highway Traffic Safety Administration in preparing for and combating real-world cyberattacks on automobiles. Although there have been no such attacks...

 

HTMLNIST Issues Streamline Guidance for Public Comment
Sutherland Asbill Brennan LLP;
Legal Alert/Article
April 27, 2016, previously published on April 25, 2016
The National Institute of Standards and Technology (“NIST”) has issued a revised version of its guidance for sharing cyber-threat intelligence. The goal of this guidance is to help improve cybersecurity operations and risk management activities through information sharing practices....

 

HTMLSteelworkers Reverse Course and Withdraw Request for Import Relief on Aluminum
Mark D. Herlach, Allison E. Speaker; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
April 27, 2016, previously published on April 25, 2016
In an unusual change of course, the United Steelworkers Union (USW) has now withdrawn the Section 201 petition it filed just last week to request temporary relief against imports of primary unwrought aluminum. According to various sources, the USW petition faced opposition from the U.S. and...

 


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