Areas of Experience
Outside Publication | Article
William Gorrod
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On June 16, the Internal Revenue Service (IRS) issued Notice 2011-54 , which provides that U.S. persons having signature authority over, but no financial interest in, foreign financial accounts in 2009 or earlier calendar yea... more
LawFlash/Client Alert | Tax LawFlash
Paul Gordon, Casey August
In a decision issued February 9, the U.S. Tax Court ruled, in part, that the partners of a law firm established as a limited liability partnership (LLP) under state law were subject to Self-Employment Contributions Act (SECA) ta... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued Notice 2011-1 (the Notice) on May 31, providing a filing extension until June 30, 2012 for certain U.S. persons with signature authority ov... more
LawFlash/Client Alert | Tax LawFlash
Charles Lubar, Olivier Couraud
On 11 May, the French Government introduced before the National Assembly an Amending Finance Bill (n°3046) for 2011 (the Bill) that proposes a significant reform of taxes on wealth and estates. Pursuant to the Bill, the tax... more
LawFlash/Client Alert | Tax LawFlash
E.S. Kate Habershon
On 23 March, UK Chancellor of the Exchequer George Osborne released his second budget. Unlike his first budget in 2010, which was a "rescue" budget containing a number of cuts, this budget is a "plan for growth" and is aimed at... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued final regulations (RIN 1506-AB08) on February 24 regarding the requirements for certain U.S. persons to file Form TD F 90-22.1, Report of F... more
Outside Publication | Article
William Zimmerman
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On February 8, the Internal Revenue Service (IRS) announced a new penalty framework allowing taxpayers to voluntarily disclose previously unreported offshore accounts and entities. The program generally provides for exemption f... more
LawFlash/Client Alert | Tax LawFlash
Gabriel Quihuis
Signed into law on December 17, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the Act) extends the temporary favorable tax treatment of gain resulting from the sale of qualified sm... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On December 22, President Obama signed into law the Regulated Investment Company Modernization Act of 2010 (the Act). The Act includes almost all of the provisions of the version of the legislation passed by the U.S. House o... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
According to the National Retail Federation’s 2010 holiday survey, total gift card spending for 2010 is estimated to reach $25 billion. [1] According to the survey, gift cards will be ... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On December 17, President Obama signed into law H.R. 4853, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the 2010 Tax Relief Act). The 2010 Tax Relief Act extends the Bush-era individua... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On December 7, the Internal Revenue Service (IRS) issued new temporary regulations providing sourcing rules for "fails charges" that may arise in the delivery-versus-payment market for Treasury securities . The new sourcing pr... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
On November 12, the Internal Revenue Service (IRS or Service) released an Action on Decision (AOD), AOD 2010-05, stating that it disagrees with the U.S. Tax Court's reasoning and decision in Veritas Software Corp. v. Commission... more
LawFlash/Client Alert | Tax LawFlash
Gabriel Quihuis
The Small Business Jobs Act of 2010 (the Act), signed into law on September 27, includes a provision that expands the existing favorable tax treatment of gain resulting from the sale of qualified small business stock. Under thi... more
LawFlash/Client Alert | Labor and Employment LawFlash
Labor and Employment Practice
On October 13, the Pennsylvania Construction Workplace Misclassification Act (the Act) was signed into law by Pennsylvania Governor Edward Rendell. The Act is designed to curtail worker misclassification in the construction ind... more
LawFlash/Client Alert | Tax LawFlash
William Zimmerman, Jarrod Huffman
On September 28, the U.S. House of Representatives passed the Regulated Investment Company (RIC) Modernization Act of 2010 (the Act), which will go a long way toward updating and streamlining a number of mutual fund tax rules. ... more
LawFlash/Client Alert | Tax LawFlash
Tax Practice
Taxpayers and advisors should give careful consideration to the changing landscape of state taxes in the context of elections under 26 U.S.C. § 338(h)(10) (hereafter I.R.C. § 338(h)(10)), a common tax-plannin... more
LawFlash/Client Alert | Tax LawFlash
Gary Wilcox
On May 21, 2010, the U.S. Department of the Treasury (Treasury) issued Notice 2010-45 (the Guidance), [1] which outlines the procedures for obtaining a valuable new 50% tax credit or equival... more
LawFlash/Client Alert | Tax LawFlash
Gary Wilcox
The Patient Protection and Affordable Care Act of 2010, as amended by the Health Care and Education Reconciliation Act of 2010 (the Healthcare Reform Law), provides for a valuable new 50% tax credit or equivalent cash grant, for... more
Presentation | Webinar
Gary Wilcox
Morgan Lewis and the National Foreign Trade Council hosted a Reuters-moderated roundtable discussion, which covered the following topics: LMSB’s International Enforcement Focus New Disclosure Requirement for Unce... more
Presentation | Speech
Wendy Unglaub
LawFlash/Client Alert | Tax LawFlash
E.S. Kate Habershon
The 2010 UK Government budget was handed down on 24 March. It was titled "Securing the recovery" and did not contain any surprises, nor changes to the corporate tax regime that will have a dramatic impact on business in the UK. ... more
LawFlash/Client Alert | Tax LawFlash
William Colgin, Jr., Neal Gordon, Barton Bassett
In a decision filed on March 22, the U.S. Court of Appeals for the Ninth Circuit reversed course and affirmed the U.S. Tax Court's decision in favor of the taxpayer in Xilinx, Inc. v. Commissioner of Internal Revenue . Xilinx... more