Summer is winding down and fall is approaching. Here are a few of the significant tax cases from the last few weeks. Tax Court YA Global Investments, LP v. Commissioner, 151 TC No. 2 (Aug. 8, 2018): The Tax Court held that withholding tax liability on effectively connected income of foreign partners is a partnership liability that constitutes a partnership item. The Tax Court has jurisdiction over the issue in a partnership-level proceeding. Illinois
A Word About Wind has published my article about offshore wind in the United States as part of its Legal Power List 2018 special report.  The article discusses how offshore wind projects, such as Vineyard Wind, have certain advantages over onshore wind, particularly with respect to tax credits for storage.  Here is a link to the special report; alternatively, if you are not a member of A Word About Wind, we are pleased to make the
The Senate convenes today at 3 p.m. The House remains in recess and will return Sept. 4. The Senate will resume consideration of H.R. 6157, the third “minibus” spending package that provides funding for Defense and Labor-HHS-Education. The chamber is expected to vote on a series of amendments to the spending legislation throughout the week. Senate leaders are aiming to take a final vote before Labor Day. Key Hearings Tuesday, 8/21 Senate Homeland Security and…
The Eversheds Sutherland SALT Team is always excited to see what kind of pets our clients and friends have. Our team features a different pet at the end of every month, and we want to feature YOURS! Featured pets will receive a fun prize from the SALT Team. The deadline for August submissions is Monday, August 27. To submit your pet to be featured, visit the Eversheds Sutherland SALT Shaker App, click “Pet of…
Transaction Costs It is a basic principle of M&A taxation that the more a seller pays in taxes on the sale of its business, the lower will be the economic gain realized on the sale; similarly, the more slowly that a buyer recovers the costs incurred in acquiring a business, the lower will be the return on its investment. In general, these principles are most often considered at the inception of an M&A transaction –…
Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 13 – 17, 2018: August 13, 2018: The IRS and Treasury withdrew and re-proposed certain portions of proposed regulations regarding the new partnership audit regime. These proposed regulations make changes to four different regulation packages under the new rules. August 15, 2018: Revenue Procedure 2018-42 extends the deadline for submitting on-cycle applications for opinion letters or pre-approved…
Director Blanco Emphasizes Investigatory Leads and Insights Into Illicit Activity Trends Culled from Nationwide BSA Data As we just blogged, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco recently touted the value of Suspicious Activity Reports (“SARs”) in the context of discussing anti-money laundering (“AML”) enforcement and regulatory  activity involving digital currency.  Shortly thereafter, Director Blanco again stressed the value of SARs, this time during remarks before the 11th Annual Las Vegas Anti-Money Laundering Conference
https://youtu.be/fEsBrOoVuwo Jen: This is the PKF Texas Entrepreneur’s Playbook. I’m Jen Lemanski, and I’m back again with Danielle Supkis Cheek, a director on our Entrepreneurial Advisory Services team. Danielle, welcome back to the Playbook. Danielle: Thanks for having me again. Jen: So a few episodes back we talked about revenue recognition. Another one of our directors has also talked about it. What are the steps a company needs to take for revenue recognition? Danielle:…
Our colleagues Matthew S. Adams and Jana Volante Walshak have authored a client alert about the Supreme Court’s recent decision in Carpenter v. United States, where the court held that cellphone location records deserve heightened protection, once again expanding the Fourth Amendment protections afforded to certain modern digital communications. And in doing so, the unusual five-justice majority led by Chief Justice Roberts has suggested a roadmap for white-collar defense lawyers to follow when strategizing…
The applicable federal rates (AFRs) under Internal Revenue Code (Code) Section 1274(d) and Code Section 7520 rate (7520 rate) for a particular month are published by the Internal Revenue Service (IRS) in a Revenue Ruling that is released around the 18th day of the immediately preceding month. Advance knowledge of the rates for the following month provides a window of opportunity for the quick or delayed implementation of income, gift, and estate-tax planning techniques in response…

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