David Saltzman

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On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs. The suspended rulings had arguably required the distributing corporation and the spun-off corporation to each independently generate current revenue. This development is welcome news for life sciences, technology, and other research and development (R&D)-focused business organizations that did not pursue a tax-free spinoff because of a perceived revenue requirement. The move comes on the heels of the IRS’s…
In this Ropes & Gray podcast, Ben Simmons, an associate in the tax group, is joined by David Saltzman, a partner in the tax group, to discuss the recent Tax Court memorandum decision, Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue. This case involved a strategy designed to permit a U.S. multinational to repatriate cash from its foreign subsidiaries without incurring current U.S. federal income tax.  …
On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research and development for future profit. The announcement is of special interest to life sciences and other technology ventures actively engaged in R&D for new pharmaceutical, medical device or other technology-based products. In particular, the announcement addresses situations where a company seeks to spin off a historic R&D-based business before its intellectual property…
In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for taxpayers, particularly multinational corporations. On September 29, 2017, in Chamber of Commerce of the United States of America et al v. Internal Revenue Service et al, the U.S. District Court for the Western District of Texas…
In this Ropes & Gray podcast, tax associate Brandon Dunn is joined by tax partners Kat Gregor and David Saltzman to discuss one of the most notable tax decisions from the fourth quarter of 2017 and its implications for taxpayers, particularly multinational corporations. On September 29, 2017, in Chamber of Commerce of the United States of America et al v. Internal Revenue Service et al, the U.S. District Court for the Western District of Texas…
On September 27, 2017, the White House and a group of congressional leaders, commonly referred to as the “Big Six”, released a joint framework for proposed tax reform. The framework sets out five goals: middle-class tax relief, simplifying tax returns for most Americans, business tax relief, ending incentives to shift jobs and capital overseas, and broadening the tax base to provide greater fairness. In addition to the specific proposals it sets forth, the framework encourages…
Rolls-Royce has agreed to pay £671 million in penalties in response to several long-running bribery and corruption investigations.  Regulators in the UK, the United States and Brazil investigated claims that Rolls-Royce had paid bribes to intermediaries to secure high-value export contracts in a number of overseas markets, including China, Brazil and Indonesia. In a press announcement, Rolls-Royce stated that it had in principle reached a Deferred Prosecution Agreement (DPA) with the UK Serious Fraud…
Many thanks to Daniel F. Roules, Olivia Zhan and Rayna Wang of Squire Sanders’ Shanghai office for preparing this article. Background Foreign companies doing business in China have focused in recent days on the case of GlaxoSmithKline (“GSK”), the British multinational producer of pharmaceuticals, biologics, vaccines and consumer healthcare products headquartered in London. Articles to date, however, have been more descriptive than analytical and have focused more on the alleged acts and potential implications for…
The most recent FCPA and anticorruption enforcement developments involving the People’s Republic of China (PRC) are summarized below. Thanks, as always, to Squire Sanders’ Shanghai Office for monitoring these enforcement actions. 1.     New law or regulation State level: (1)     It was reported on July 6, 2013 that the Supreme People’s Procuratorate (“SPP”) of China issued a Code of Conduct for the Law Enforcement of People’s Procuratorate Prosecutors in Civil and Administrative Cases (“Code of Conduct”).…