Statutory interpretation and congressional intent will play a pivotal rol= e in a U.S. Supreme Court appeal over whether $13.3 million in stock option= s given to employees of a Canadian railroad company is taxable compensation= , a case that will see the justices delve into what exactly constitutes =E2= =80=9Cmoney remuneration.=E2=80=9D

Thursday, January 18, 2018

TOP NEWS

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Analysis

Meaning Of Money K= ey In $13M High Court Stock Options Suit

Statutory interpretation and congressional intent will play a pivotal= role in a U.S. Supreme Court appeal over whether $13.3 million in stock op= tions given to employees of a Canadian railroad company is taxable compensa= tion, a case that will see the justices delve into what exactly constitutes= “money remuneration.” Read more »

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ABA Tax Section Imp= lores Congress To Adequately Fund IRS

The chairwoman of the American Bar Association’s tax section on= Tuesday urged Congress to provide adequate funding for the IRS, cautioning= that in light of the Tax Cuts and Jobs Act, P.L. 115-97, the agency will f= ace difficulties effectively administering and collecting tax revenues with= out additional funds. Read more »

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Apple Expects $38B = Tax Hit On Overseas Cash From GOP Bill

Apple Inc. said Wednesday it expects to pay $38 billion in taxes= on repatriated funds brought from overseas as required by the new federal = tax overhaul, noting it would likely be the largest payment of its kind eve= r made. Read more »

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Eaton Clashes With = IRS In Tax Court Over Foreign Income

Eaton Corp. clashed with the IRS in the U.S. Tax Court on Wednesday o= ver the question of when a foreign subsidiary’s income becomes taxabl= e in the U.S., in the latest skirmish between the power management company = and the federal tax agency. Read more »

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House May Vote On Spendin= g Bill Delaying ACA Taxes

The House could vote as early as Thursday on a short-term government = funding bill that would delay the onset of three taxes originally enacted i= n the Affordable Care Act health care reform law, but the legislation could= stall as Republicans and Democrats disagree on what should be included in = the measure. Read more »

FEDERAL

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IRS Delays Penalty For = Excise Tax On Medical Devices

The Internal Revenue Service will not impose a penalty on medical dev= ice manufacturers that fail to make excise tax deposits due in the first th= ree quarters of the year, according to an announcement on Wednesday. Read more »

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Greenberg Traurig F= aces DQ Bid By Onetime Vet-Led Client

Florida-based government contractor National Sourcing Inc. asked a co= urt Tuesday to disqualify Greenberg Traurig PA from representing a subcontr= actor and others because of the firm's previous work for NSI, a disabl= ed veteran-owned company. Read more »

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'Jersey Shore' Sta= r, Brother To Plead Guilty In Tax Case

“Jersey Shore” star Michael “The Situation” S= orrentino and his brother Marc Sorrentino have agreed to plead guilty in th= eir criminal case over tax-related charges instead of going to trial next m= onth, according to a government letter on Wednesday to a New Jersey federal= judge. Read more »

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Utah Law Can't Res= train Fed. Tax Collection, 10th Circ. Told

The U.S. government appealed to the Tenth Circuit on Tuesday, after a= Utah federal court knocked down its bid to collect approximately $1.5 mill= ion in estate taxes from the heirs of a hotel and casino operator in Nevada. Read more »

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Tax-Dodging Million= aire Tells 2nd Circ. $10M Fine Too Big

Moneyman Morris Zukerman, currently incarcerated for decades of massi= ve tax frauds, told the Second Circuit on Wednesday he deserves resentencin= g because he got no cogent explanation for why he was smacked with a $10 mi= llion fine that was “orders of magnitude” higher than anything = his criminal peers ever got. Read more »

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Martha’s Vin= eyard Exorcist Gets Over 2 Years, $4.2M Penalty

A prominent East Coast psychic was sentenced on Wednesday to two year= s and two months in prison and agreed to repay more than $4.2 million of in= come plus taxes she admitted to concealing over seven years that an elderly= Martha's Vineyard woman paid to undergo exorcism routines. Read more »

STATE & LOCAL

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NY Tax Dept. Propos= es State Law Changes In Light Of TCJA

The New York State Department of Taxation and Finance presented Democ= ratic Gov. Andrew Cuomo with a preliminary report Wednesday outlining poten= tial modifications to the state’s tax code that could help minimize t= he impact the Tax Cuts and Jobs Act, P.L. 115-97, is expected to have in hi= gh-tax states. Read more »

INTERNATIONAL

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Top EU Court Says Co. = Not Exempt From Dirty Money Laws

The European Union’s highest court on Wednesday ruled against a= Czech company's claim that it should not have been subject to a regulatory= probe, saying the firm’s arguments were not consistent with the EU&#= 8217;s objective to prevent money laundering and terrorist financing in the= financial sector. Read more »

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EU To Remove Panama, Ot= hers From Tax Haven 'Blacklist'

The European Union announced Tuesday that it will remove eight jurisd= ictions, including Panama, from its list of alleged tax havens, prompting c= riticism from the European Parliament members tasked with investigating tax= avoidance in the wake of the Panama Papers scandal. Read more »

Q&A

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Q&A

A Chat With Davis Wright CSO Mar= k Usellis

In this monthly series, legal recruiting experts Amanda Brady and Amy= Mallow of Major Lindsey & Africa interview law firm management from Am Law= 200 firms about how they are navigating an increasingly competitive busine= ss environment. The second conversation is with Mark Usellis, chief strateg= y officer for Davis Wright Tremaine LLP. Read more »

EXPERT ANALYSIS

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Tax Overhaul Is A = Mixed Blessing For The Finance Industry

The 40 percent reduction in the statutory corporate rate stands to yi= eld major benefits for the finance sector. But other provisions in the Tax = Cuts and Jobs Act, including international anti-abuse laws, may unintention= ally burden banks, say Michele Alexander and Ryan Davis of Bracewell LLP. Read more »

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Tax Reform Reshuffles The Dec= k For Outsourcing

The new tax bill changes the calculus for cross-border services outso= urcing and cloud agreements. For a U.S.-parented provider deciding whether = to increase its U.S. operations relative to non-U.S. operations, several pr= ovisions must be considered, including the deduction for foreign-derived in= tangible income, the tax on global intangible low-taxed income and the base= erosion and anti-abuse tax, say attorneys at Mayer Brown LLP. Read more »

LEGAL INDUSTRY

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Analysis

How A Supreme Court La= bor Case Could Reshape The Bar

Predictions that the Supreme Court will strike down a decades-old la= bor law precedent have led some to ask: Is America’s most common bar = association structure built on a legal house of cards? Read mo= re »

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Analysis

Don't Expect The = Law Firm Merger Market To Slow Down Soon

Mergers between law firms reached an all-time high in 2017 thanks in= part to generational shifts in firm leadership and a rapidly evolving lega= l landscape, but don't expect the legal merger market to slow down as conso= lidation in the industry looks set to keep rolling. Read m= ore »

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Male Clients Show= 'Clear Gender Bias' For Men As Lead Attys

Male clients are less likely than female clients to select female le= ad partners from their law firms, according to the latest Star lawyer nomin= ations from a multinational study by London research firm Acritas published= Wednesday. Read more »

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Ex-Sen. Dodd, Eli = Lilly Litigation Head Join Arnold & Porter

Arnold & Porter Kaye Scholer LLP on Tuesday said former U.S. Sen= . Christopher Dodd will join the firm in Washington, D.C., as part of its l= egislation and public policy group, while the former head of litigation for= Eli Lilly & Co. will come aboard in its life sciences and health care = regulatory practice. Read more »

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When And How To Communica= te With Pro Se Litigants

Given the surprisingly large volume of pro se litigation in the Unit= ed States, there will inevitably be times when you need to communicate with= self-represented litigants. Following Model Rule of Professional Conduct 4= .3 can help you minimize risks and maximize payoff, say attorneys at Shook = Hard & Bacon LLP. Read more »

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Trump Taps 5th Circ= . Judge To Be Ambassador To Argentina

President Donald Trump announced Wednesday he intends to nominate Fi= fth Circuit Judge Edward C. Prado to be the United States’ ambassador= to the Argentine Republic, citing his 35 years of experience as a federal = judge. Read more »

JOBS
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Senior Tax Associate
Burns & Levinson
Boston, Massachusetts

Tax & Estate Planning Associate
Schwabe, Williamson & Wyatt
PORTLAND, Oregon

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COMPANIES

Altman Weil Inc.

American Bar Associ= ation

American Federation of State, County and Municipal Employees<= /a>

Apple Inc.

California Tea= chers Association

Canadian Nat= ional Railway Company

Citigroup Inc.

Eaton Corporation

Eli Lilly and Company

General Electric Co= mpany

General Motors

Major Lindsey & Afric= a

Morgan Stanley

Motion P= icture Association of America

State Ba= r Association of North Dakota

State Bar of Arizona<= /p>

State Bar of Californi= a

Tax Foundation

Twitter Inc.

Washington Post Co.

Zeughauser Group LLC<= /p>

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U.S. Supreme Court

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