Morgan Lewis
216 Publications Found
07/01/11 Income Tax Controversy Trends: Some States Follow Federal Approaches or Offer Amnesty to Raise Revenue, BNA's Weekly State Tax Report

Outside Publication | Article
William Gorrod

06/20/11 Two More Extensions: IRS and FinCEN Issue Extensions for Certain FBAR Filers in IRS Notice 2011-54 and FinCEN Notice 2011-2

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

06/06/11 Tax Court Decision Subjects LLP Service Providers/Equity Partners to Self-Employment Tax

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

06/03/11 FinCEN Issues Extension for Certain FBAR Filers

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

06/03/11 Reform of French Taxes on Wealth and Estates

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

03/24/11 A Budget for Growth and Reform: Britain Is Open for Business

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

03/11/11 FinCEN Issues Final FBAR Regulations for Certain U.S. Persons Holding Foreign Financial Accounts

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

Spring 2011 Two Recent Private Letter Rulings Provide a Rationale for Determining When Certain Derivative Contracts Will Be Considered Securities Under Code Sec. 851(b)(2) and Will Produce Qualifying Income for a Regulated Investment Company, Journal of Taxation of Financial Products, Vol. 9 Issue 3

Outside Publication | Article
William Zimmerman

02/09/11 IRS Announces Second Special Voluntary Disclosure Initiative for Offshore Accounts

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

12/23/10 Favorable Tax Treatment of Certain Small Business Stock Extended for One Year

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

12/23/10 President Obama Signs RIC Modernization Act of 2010

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

12/21/10 Unclaimed Property Laws: Gift Card Stocking Stuffers Can Become Lumps of Coal for Unwary Retailers

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

12/20/10 Tax Relief Act Includes Incentives for Business and Investment

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

12/08/10 IRS Issues Sourcing Rules for “Fails Charges” That Impact the Application of U.S. Withholding Tax Rules

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

11/19/10 IRS Disagrees with Veritas But Won't Appeal

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

10/27/10 New Law Temporarily Expands Favorable Tax Treatment of Certain Small Business Stock

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

10/14/10 Pennsylvania Law Provides Stringent Penalties for Misclassification of Construction Workers

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

10/06/10 House Passes RIC Modernization Act of 2010

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

09/28/10 Section 338(h)(10) Elections for S Corporations: Traps for Nonresident Shareholders Under a Changing State Law Landscape

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

05/24/10 Treasury Issues Guidance for 50% Tax Credit/Cash Grant for Life Sciences Companies

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

04/21/10 New 50% Tax Credit/Cash Grant for Life Science Companies Requires Timely Determination of Eligibility and Application

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

04/09/10 The Changing Tax Landscape for Multinational Companies

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

03/26/10 Tax Compliance Issues, presented at the Clean Energy Forum, Camden, NJ

Presentation | Speech
Wendy Unglaub

03/25/10 United Kingdom budget 2010: Securing the recovery

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

03/23/10 IRS Loses Major International Tax Case: Ninth Circuit Changes Course, Affirms Decision in Xilinx

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