The Republicans=E2=80=99 sweeping tax legislation radically revised the t= reatment of overseas income in a way that undermines tax treaties at a time= when U.S. multinational businesses will need them to resolve cross-border = disputes that are on the horizon, specialists say.

Wednesday, January 10, 2018

TOP NEWS

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Analysis

New Tax Law At Odds Wi= th Treaties, International Policy

The Republicans’ sweeping tax legislation radically revised the= treatment of overseas income in a way that undermines tax treaties at a ti= me when U.S. multinational businesses will need them to resolve cross-borde= r disputes that are on the horizon, specialists say. Read more »

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Tax Court Says I= RS Didn't Need Whistleblower For Settlement

An Arizona man who alerted the IRS to the possibility that his former= employer may owe taxes on allegedly unpaid overtime wages can’t get = a share of the agency’s settlement with the company during bankruptcy= proceedings after the U.S. Tax Court ruled Tuesday that the settlement was= a result of standard IRS procedures and not the whistleblower’s clai= m. Read more »

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Perrigo Fights Depo= sition Of Dexcel Workers In $163M Bout

Generic pharmaceutical giant Perrigo Co. PLC pushed a Michigan federa= l judge Monday to deny the government’s request to acquire court test= imony from four employees of Israeli manufacturer Dexcel Pharma Technologie= s Ltd. in a fight over $163 million in refunds. Read more »

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'Jersey Shore' Star= , Brother Reject Plea Deals In Tax Case

“Jersey Shore” star Michael “The Situation” S= orrentino and his brother, Marc Sorrentino, said Tuesday in New Jersey fede= ral court that they had each rejected a plea offer made by the government l= ast month in their criminal case over tax-related charges. Read more »

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Dems Ask If Adminis= tration’s Pressuring IRS On Tax Tables

Senate Finance Committee ranking member Ron Wyden, D-Ore., and House = Ways and Means ranking member Richard Neal, D-Mass., in a Monday letter que= stioned whether the Trump administration was wrongfully pressuring the IRS = to produce 2018 withholding tables that would result in a systematic underw= ithholding of federal taxes from taxpayer earnings. Read more »

FEDERAL

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Ryan Says Tax Act S= purs Cos. To Stay In US, Boost 401(k)s

Assurant Inc. announced Tuesday that it plans to remain a Delaware co= rporation, and Aflac recently said it would boost its employee 401(k) match= ing, decisions that Republican House Speaker Paul Ryan linked to the federa= l tax overhaul. Read more »

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US Says Amici Not H= elpful In Unique $21M Tax Refund Fight

The U.S. government blasted a show of support for Swiss insurer Starr= International Co. Inc. from a tax attorney and two tax law professors in a= $21 million tax refund lawsuit, saying in a court filing on Monday that th= e practitioners aren’t doing much to help resolve unique, threshold i= ssues. Read more »

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Typo Should Invalid= ate IRS Lien, Property Investor Says

An IRS typo on a notice of federal lien that misspelled a taxpayer= 217;s first name is not a minor issue and should prevent the government fro= m enforcing a lien against the affected property, property holders told an = Illinois federal court Monday. Read more »

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US Says Executor Of Tax Ev= ader's Estate Owes $9.2M

The U.S. government on Tuesday asked a California federal judge to gr= ant summary judgment in a $9.2 million case against the executor of a tax e= vader’s estate. Read more »

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5th Circ. Solidifi= es Texas Doctor's Tax Evasion Conviction

The Fifth Circuit on Monday affirmed the conviction of a plastic surg= eon for failing to account for and pay federal payroll taxes that had been&= #160;withheld, rejecting his claims that a jury received improper instructi= ons as to proving his guilt and lacked evidence to convict. Read more »

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Estate Seeks $1.1M Refun= d After Protracted IRS Battle

The executor and trustee of an estate sued the federal government in = California federal court on Monday to recover about $1.1 million in collect= ed estate tax stemming from the disallowance of a claimed marital deduction= and administrative expenses. Read more »

STATE & LOCAL

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Analysis

Millionaires' Tax Debat= e Continuing In Cities, States

With the newly signed federal tax reform law, H.R. 1, widely characte= rized as disproportionately benefiting the wealthy, the debate over so-call= ed millionaires' taxes is advancing in several state and city jurisdictions= , a move that could theoretically take back some of the potential windfall = for the affluent. Read more »

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Firm Says Ex-Partner Ex= ploited Widow To Sign Over $2M

The now-dissolved firm of a Miami tax lawyer who killed himself filed= suit Monday against the attorney's former law partner, accusing him of sch= eming to keep $2 million in insurance policy proceeds from the man’s = wife. Read more »

INTERNATIONAL

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EU Lawmakers Mull S= tate Variances For Blocwide Pensions

The European Parliament has published proposals for a new regulation = on a blocwide personal pensions regime aimed at promoting competition and a= llowing customers to move their retirement investments across the EU. Read more »

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South Korea Expand= s Tax Credits, Changes Other Regulations

South Korea announced on Monday that it was expanding tax credits for= investment, while broadening the capital gains tax on large taxpayers and = tightening anti-evasion reporting rules. Read more »

EXPERT ANALYSIS

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What Tax Reform Means For = The Energy Sector: Part 2

Companies in the energy sector will be affected by many provisions in= the new tax law, including changes to base erosion taxation, the corporate= alternative minimum tax, net operating losses, contributions in aid of con= struction, partnership and other pass-through income and Section 199 domest= ic production activities, say attorneys with Eversheds Sutherland LLP. Read more »

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Top 10 Employer Resolutions For 2018

Last year employers watched as a variety of regulations were rolled b= ack to pre-Obama administration status. Allegra Lawrence-Hardy and Bonnie B= urke of Lawrence & Bundy LLC discuss what happened in 2017, the development= s employers should be alert to this year, and the resolutions they should m= ake to protect their company and employees. =09=09=09=09

Opinion

This Year, Let’s Invest In= Lawyer Resiliency

Highly profitable companies have comprehensive corporate wellness pro= grams that realize plateauing health care costs, greater employee engagemen= t, and a demonstrable competitive advantage. The legal field needs a simila= r awakening, says Rudhir Krishtel, a former partner of Fish & Richardson an= d senior patent counsel at Apple. Read more »

LEGAL INDUSTRY

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Analysis

7 Habits Of Success= ful Litigators & How They Apply To You

Being a litigator requires organization, discipline and efficiency, = and even the most revered litigators admit there are challenges to staying = organized and progressing on projects. Here, Law360 looks at seven daily ha= bits litigators have adopted to help them manage busy schedules and stay on= task to attain success. Read more »

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Big Data Drives Innovation= And New Risks For GCs

While data provides the foundation for such advancements as artifici= al intelligence chatbots and autonomous vehicles, it also carries new = and unintended legal implications, according to a report released Tuesday b= y Crowell & Moring LLP. Read more »

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Renco Sues Ex-Kaye Schol= er Attys Over $214M Verdict

The Renco Group sued its former attorneys from Kaye Scholer in New Y= ork state court Monday, blaming the counsel for an “inconsistent̶= 1; jury verdict that cost the company and its billionaire owner Ira Rennert= $214 million in damages over fraudulent transfers. Read more &r= aquo;

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Judge Wood Talks To= Law360 About Rooting Out Harassment

Law clerks who worked for Ninth Circuit Judge Alex Kozinski believed= court rules barred them from speaking out about his alleged harassment = 212; a misunderstanding that Seventh Circuit Chief Judge Diane Wood hopes s= he can prevent through a new committee on sexual harassment, she told Law36= 0 in an interview Tuesday. Read more »

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IP Firm Stakes S= urvival On War Against Non-Atty TM Services

A California attorney has lodged his eighth complaint in just three = weeks over online trademark registration services, telling Law360 on Tuesda= y that his litigation war over such companies’ use of non-lawyers for= legal work is a “matter of survival” for his firm. Read more »

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LA Developer Can Re= do Lewis Brisbois Office Fire Claims

A California judge on Tuesday gave a Los Angeles developer another s= hot at his counterclaims that the state’s failure to fix a broken fen= ce gave an arsonist the means to start a fire that caused $80 million of da= mage, including at Lewis Brisbois Bisgaard & Smith LLP’s former h= igh-rise outpost. Read more »

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Kamala Harris, Cory= Booker Get Seats On Judiciary Panel

Sens. Kamala Harris, D-Calif., and Cory Booker, D-N.J., on Tuesday w= ere set to have seats on the U.S. Senate Judiciary Committee following a sh= ake-up after the resignation of Sen. Al Franken, D-Minn., and election of S= en. Doug Jones, D-Ala. Read more »

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Senate Fills 1st T= enn. Judicial Post, Advances 2nd Nominee

The Senate voted to approve President Donald Trump's first federal j= udge of the new year, confirming Frost Brown Todd LLC member William Campbe= ll Jr. to an empty judge post in Tennessee on Tuesday, as well as advancing= a nominee to fill a second vacancy in the state. Read mo= re »

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Series

My Supreme Court Debut: An Impas= sioned Plea

As I rose to the lectern for my first argument at the U.S. Supreme C= ourt, I realized that the court had to that point heard over 90 minutes of = oral argument about California’s "three strikes" law, but no one R= 12; not any of the lawyers, not any of the justices — had expressed o= utrage that a man could spend life in prison for shoplifting, says Erwin Ch= emerinsky, dean of UC Berkeley Law School. Read more »

JOBS
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COMPANIES

Digital Realty Trus= t Inc.

General Electric Co= mpany

LegalZoom.com Inc.

New York University

Perrigo Co. PLC

Pnc Financial= Services Group,The

Prudential Financia= l Inc.

The Renco Group

U.S. Bancorp

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Government Acc= ountability Office

Internal Revenue Servi= ce

Judici= al Conference of the United States

National Labor R= elations Board

Office of Fore= ign Assets Control

Securities a= nd Exchange Commission

U.S. Depart= ment of Homeland Security

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