Morgan Lewis
224 Publications Found
page 1 of 12
01/24/12 Broad Regulations for Foreign Financial Asset Reporting

LawFlash/Client Alert | Tax LawFlash
T. Wu, Gabriel Quihuis

Proposed and temporary Treasury regulations expand upon, and perhaps duplicate, other required information reporting with respect to foreign financial assets held by certain U.S. taxpayers.

01/24/12 Loi de Finances Rectificative pour 2011 et Loi de Finances Initiale pour 2012 [France: Amending Finance Law for 2011 and Initial Finance Law for 2012]

LawFlash/Client Alert | Tax LawFlash
Olivier Couraud

La Loi de Finances Rectificative pour 2011 et la Loi de Finances Initiale pour 2012 confirment la politique de rigueur mise en œuvre par le Gouvernement depuis 2011, au travers d'une fiscalité accrue pour les entreprises et les particuliers. [The Amending Finance Law for 2011 and the Initial Finance Law for 2012 confirm the austerity measures for enterprises and individuals that the French Government set up in 2011.]

01/03/12 D.C. Nonprofit Corporation Law Changes for 2012

LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Celia Roady, Matthew Elkin, Edward Chaney, Kimberly Eney

Revisions to the District of Columbia Nonprofit Corporation Act affect the governance and internal operations of certain D.C. nonprofits.

10/19/11 Making Waves on the Left Coast: California’s Ever-Changing Sales Factor Rules, IPT October 2011 Tax Report

Outside Publication | Article
William Gorrod, Kimberley Reeder

10/18/11 IRS Creates New Voluntary Classification Settlement Program Providing Companies the Opportunity to Reclassify Independent Contractors and Limit Liability

LawFlash/Client Alert | Tax LawFlash
Robert Martinelli, David Fuller, Miriam Fisher

The Internal Revenue Service (IRS) has released details regarding its new Voluntary Classification Settlement Program (VCSP) in Announcement 2011-64. [1] The VCSP provides taxpayers a new opp... more

10/18/11 OVDI Is Over — What’s Next For Voluntary Disclosures?, Tax Notes

Outside Publication | Article
Mark Matthews

08/26/11 Recent IRS Notices Provide Supplemental FATCA Guidance and Phased-in Implementation

LawFlash/Client Alert | Tax LawFlash
William Zimmerman, Gabriel Quihuis

The Internal Revenue Service (IRS) recently issued its second and third notices concerning the implementation of the Foreign Account Tax Compliance Act (FATCA). Notice 2011-34 (the Second Notice) was issued on April 8, 2011 and... more

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

10/07/10 Effects of Bringing Foreign Entities into a Combined Return, presented at the TEI Annual Conference, Chicago

Presentation | Speech
Kimberley Reeder

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