LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Celia Roady
On Monday, December 5, 2005, the Treasury Department issued revised Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities. The revised Guidelines replace the Guidelines issued b... more
LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar,
Ann Batlle,
Drew Porter,
Celia Roady,
Carolyn Ward
On November 18, 2005, the Senate passed the Tax Relief Act of 2005 (S. 2020), which contains several significant modifications to the tax rules governing exempt organizations and charitable giving. The companio... more
Outside Publications | Chapter
Patrice Lefèvre-Péaron
LawFlash/Client Alert | Tax LawFlash
Tax
On October 27, the Internal Revenue Service (IRS) announced a short-term settlement initiative for taxpayers involved in a broad array of transactions that the IRS deems abusive. Eligible participants in the in... more
Outside Publications | Article
Frances Babb
LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar,
Ann Batlle,
Drew Porter,
Celia Roady,
Carolyn Ward
There has been some significant activity in Congress over the past couple of weeks on tax issues affecting the charitable sector. On September 21, 2005, Congress enacted temporary tax relief legislation related... more
Outside Publications | Article
Patrice Lefèvre-Péaron
White Paper | Morgan Lewis White Paper
Christina Harper,
Kenneth Kail
The U.S. Treasury and the Internal Revenue Service recently published regulations governing practice before the Internal Revenue Service, which are effective for written U.S. federal tax advice provided after June 20, 2005.<... more
LawFlash/Client Alert | Tax-Exempt Organizations LawFlash
Tomer Inbar,
Ann Batlle,
Celia Roady,
Carolyn Ward
The attorneys general in certain states – including New York and Massachusetts – have begun to focus increased scrutiny on the corporate governance and fundraising practices of non-profit organizations, in line with sim... more
Outside Publications | Article
Patrice Lefèvre-Péaron
LawFlash/Client Alert | Litigation LawFlash
Miriam Fisher,
John Hemann
On April 26, 2005, the United States Supreme Court upheld criminal convictions arising from a scheme to avoid taxation by a foreign government. The decision in Pasquantino v. United States , 125 S. Ct. ... more
Presentation | Speech
Carolyn Ward
Outside Publications | Article
Anne Tolila,
Patrice Lefèvre-Péaron
Presentation | Speech
Ann Batlle
Presentation | Speech
Carolyn Ward
Presentation | Speech
Ann Batlle
Presentation | Speech
Carolyn Ward
White Paper | Morgan Lewis White Paper
Gary Wilcox
This White Paper explores some of the implications of the Long Term Capital Holdings decision. It covers the analysis of not only lease strips and their progeny, known as “viral stock,” but also other sh... more
White Paper | Morgan Lewis White Paper
Miriam Fisher
The Long Term Capital Holdings decision, issued by the U.S. District Court for the District of Connecticut on August 27, 2004, presents a microscopic case study of the heyday of sophisticated and aggressive tax planni... more
LawFlash/Client Alert | Tax LawFlash
Tomer Inbar,
Ann Batlle,
Celia Roady,
Carolyn Ward
On January 27, the Joint Committee on Taxation (“JCT”) released a 430-page report describing proposals to curtail tax shelters, close loopholes, and address other areas of noncompliance. The report, “Options to... more
LawFlash/Client Alert | Tax LawFlash
Tax
One of the most important provisions of the American Jobs Creation Act of 2004 that Congress passed last October is an 85% exclusion for certain dividends received by U.S. corporations from controlled foreign corporatio... more
LawFlash/Client Alert | Tax LawFlash
Richard Zarin
Last week, the U.S. Treasury issued proposed regulations that for the first time would allow tax-free treatment for cross-border mergers organized under foreign law. These regulations, if adopted, will put non-... more
Presentation | Speech
Carolyn Ward
Outside Publications | Article
Ann Batlle
Presentation | Speech
Carolyn Ward