Return-Path: Received: from vps.transocean.com by vps.transocean.com with LMTP id iAmtG7iwYVqAZgAAInt2oQ ; Fri, 19 Jan 2018 00:47:52 -0800 Return-path: Envelope-to: bruce@transocean.com Delivery-date: Fri, 19 Jan 2018 00:47:52 -0800 Received: from o4.mailings-q.law360.com ([167.89.1.233]:25892) by vps.transocean.com with esmtps (TLSv1.2:ECDHE-RSA-AES128-GCM-SHA256:128) (Exim 4.89_1) (envelope-from ) id 1ecSKt-0006ru-SB for bruce@transocean.com; Fri, 19 Jan 2018 00:47:52 -0800 DKIM-Signature: v=1; a=rsa-sha1; c=relaxed/relaxed; d=law360.com; h=from:to:subject:mime-version:content-type:content-transfer-encoding; s=s1; bh=Nd+4zAhHzv1LzhsM+OldD7mXJFE=; b=AA/ohOwbdCenKo7koJ8yJ29 eRiXvu1pjKbMcKXsZtXs9lbZ3HMe/co7ztPUeuUPJ94N21OZjcSB7OOM7hFA7nxS jsycTMihK+cDt/avPOq8/l82jk6YFEgnJuXu2N2g8v8LC3zi3NpSYjFEVOs2qScd oHa8KXobTHnAW8iTVQ6I= Received: by filter1229p1mdw1.sendgrid.net with SMTP id filter1229p1mdw1-29474-5A61B086-6 2018-01-19 08:47:02.821807614 +0000 UTC Received: from www.law360.com (ec2-34-202-165-210.compute-1.amazonaws.com [34.202.165.210]) by ismtpd0006p1iad1.sendgrid.net (SG) with ESMTP id 0pwvIh__R46qrKpKmQZ1sw for ; Fri, 19 Jan 2018 08:47:02.844 +0000 (UTC) Date: Fri, 19 Jan 2018 08:47:03 +0000 (UTC) From: Tax Law360 To: bruce@transocean.com Message-ID: <5a61b086afafa_56c2ae208e5cf587053c9@ip-172-30-200-9.mail> Subject: Tax Court Backs Treasury Regs In $377M Foreign Income Suit Mime-Version: 1.0 Content-Type: text/html; charset=UTF-8 Content-Transfer-Encoding: 7bit X-SG-EID: Opio7iv9VGQ4tDJiJszIh3zd7qYkeM6M7FLocQY/BAXHxu1uj4texe7OP4b4HkL2neCg+qjnLSep6D MhbqqmQ5GW+ArkWiH0Tf65+DLZzIxFE4Me0y+igkXyT2Ejiq3DZAJNgDxG1oPogq/I5NNLKKdxhvv9 jndcf8Je3HIWgtCNI5QPD2Yjs54S2aWh0TIGsXbPbxT5CwirdCN1xBbjUg== X-Spam-Status: No, score=1.6 X-Spam-Score: 16 X-Spam-Bar: + X-Ham-Report: Spam detection software, running on the system "vps.transocean.com", has NOT identified this incoming email as spam. The original message has been attached to this so you can view it or label similar future email. If you have any questions, see root\@localhost for details. Content preview: The U.S. Tax Court on Thursday upheld regulations issued by the U.S. Department of the Treasury governing income from a controlled foreign corporation, saying an affiliate of commodities trader Susquehanna International Group LLP owes taxes on some $377 million in income. TAX [...] Content analysis details: (1.6 points, 3.0 required) pts rule name description ---- ---------------------- -------------------------------------------------- 0.0 URIBL_BLOCKED ADMINISTRATOR NOTICE: The query to URIBL was blocked. See http://wiki.apache.org/spamassassin/DnsBlocklists#dnsbl-block for more information. [URIs: law360.com] -0.0 T_RP_MATCHES_RCVD Envelope sender domain matches handover relay domain -0.0 SPF_PASS SPF: sender matches SPF record 0.0 HTML_FONT_LOW_CONTRAST BODY: HTML font color similar or identical to background 0.0 HTML_MESSAGE BODY: HTML included in message 0.7 MIME_HTML_ONLY BODY: Message only has text/html MIME parts 0.8 BAYES_50 BODY: Bayes spam probability is 40 to 60% [score: 0.5000] 0.1 DKIM_SIGNED Message has a DKIM or DK signature, not necessarily valid 0.0 T_DKIM_INVALID DKIM-Signature header exists but is not valid 0.0 LOTS_OF_MONEY Huge... sums of money X-Spam-Flag: NO
The U.S. Tax Court on Thursday upheld regulations issued by the U.S. Department of the Treasury governing income from a controlled foreign corporation, saying an affiliate of commodities trader Susquehanna International Group LLP owes taxes on some $377 million in income.
Law360 Tax TAX
Friday, January 19, 2018 Follow Tax Law360
TOP NEWS

Tax Court Backs Treasury Regs In $377M Foreign Income Suit

The U.S. Tax Court on Thursday upheld regulations issued by the U.S. Department of the Treasury governing income from a controlled foreign corporation, saying an affiliate of commodities trader Susquehanna International Group LLP owes taxes on some $377 million in income. Read more »

House OKs Spending Bill To Head Off Gov't Shutdown

The U.S. House of Representatives on Thursday approved a short-term spending bill to keep the government funded for several more weeks, but the threat of a government shutdown loomed as the bill moved to the Senate, where passage remains uncertain. Read more »

Amazon Trims List Of 'HQ2' Contenders To 20

Amazon pared down its list of potential locations for a second North American headquarters to 20, saying Thursday it will decide from a select group of candidates that includes New York City, Los Angeles, Chicago, Austin, Philadelphia, Miami and Newark, New Jersey. Read more »

Stadium Can't Apply Reduced VAT To Tours: Top EU Court

The operator of an Amsterdam sports arena can’t apply a reduced value-added tax rate to the cost of tours, the European Union’s top court ruled on Thursday, finding that a portion of the tour featuring access to a museum wasn’t a separate cultural service that warranted a lower rate. Read more »

FEDERAL

Renewable Energy Grant Bout Must Go To Trial, Judge Says

Two energy companies must take their lawsuit to trial in a dispute against the government over $24 million in renewable energy cash grants after a U.S. Court of Federal Claims judge denied both sides’ bids for early wins on Wednesday. Read more »

Retailer Gets 2 Years For $5.6M Tax Fraud Scheme

A California man who operated retail locations in the state was sentenced Wednesday to two years in prison after pleading guilty to failing to pay $5.6 million in sales, income and payroll taxes, the California attorney general announced. Read more »

INTERNATIONAL

EU Launches Probe Into Poland's Tax Scheme For Shipyards

The European Commission has announced that it is investigating Poland’s low flat-rate sales tax for shipyards operating within the nation's borders, saying the policy is possibly flouting European Union state aid rules by giving a selective advantage to companies in the country.  Read more »

EXPERT ANALYSIS

Will Tax Reform Affect Utility Rates?

While some have trumpeted massive refunds awaiting utility customers following the federal corporate tax rate reduction from 35 percent to 21 percent, there are statutory, judicial and regulatory considerations and guiding principles that limit the extent to which such savings can and should be shared with utility ratepayers, say Bradley Seltzer and Amish Shah of Eversheds Sutherland LLP. Read more »

Using Section 83(i) To Take Advantage Of New Tax Code

Last month the Tax Cuts and Jobs Act introduced a new section of the Internal Revenue Code that provides for the deferral of taxation on certain qualified equity grants to employees of eligible corporations. Marc Fosse and Angel Garrett of Trucker Huss APC explain why qualified equity grants can be a helpful tax strategy for employees and an excellent recruiting, retention and incentive program for employers. Read more »

LEGAL INDUSTRY

Analysis

Sedgwick's Final Years Saw Swift Growth And Rapid Decline

The San Francisco office that formerly housed the headquarters of Sedgwick LLP will formally shut its doors this week, closing the curtain on the 85-year-old firm. Here, Law360 takes a look back at the firm's history and the events that led to its closing. Read more »

Analysis

By The Numbers: A Snapshot Of Trump’s First Year

Beneath the political chaos that’s hovered over President Trump’s first year in office has been a concerted effort to put the brakes on Washington’s regulatory machine and seat a host of conservative judges on the federal bench. Here’s how the administration is faring. Read more »

8 Partners Leave Quinn Emanuel To Form New Firm

Eight New York-based partners at Quinn Emanuel Urquhart & Sullivan LLP, including three practice group heads, are leaving the firm to start their own practice, Law360 confirmed on Thursday. Read more »

Atty Agrees To Disbarment For Filming Women In Restrooms

The general counsel of a Tampa, Florida-based maintenance and repair company has agreed to be disbarred after he was caught using cameras in the women's restrooms at the company's facility to covertly film female employees. Read more »

Senate Panel Advances Trump BigLaw Picks For DOJ, Judges

The Senate Judiciary Committee pushed through close to two dozen of President Donald Trump’s nominees on Thursday, including a number of BigLaw partners intent on filling vacant U.S. Department of Justice roles and appellate and trial judge posts. Read more »

Law360's Weekly Verdict: Legal Lions & Lambs

Akin Gump Strauss Hauer & Feld LLP and Skadden Arps Slate Meagher & Flom LLP rose to the top of the legal lions list this week after a federal judge threw out a roughly $350 million False Claims Act verdict against the law firms’ nursing home operator client while IP boutique Carlson Caspers Vandenburgh Lindquist & Schuman PA landed on the legal lambs list after the Federal Circuit junked its client’s $24 million trial win on claims that Briggs & Stratton infringed its lawn mower patent. Read more »

JOBS
Search full listings or advertise your job opening

Senior Tax Associate
Burns & Levinson
Boston, Massachusetts

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

Law360 Pro Say Podcast

Listen to our new podcast here

LAW FIRMS

Akin Gump

Boies Schiller

Carlson Caspers

Drinker Biddle

Eversheds Sutherland

Frost Brown Todd

Heurlin Potter

Jones Day

King & Spalding

Kirkland & Ellis

Morris Nichols

Ogletree Deakins

Orrick Herrington

Quinn Emanuel

Ropes & Gray

Sedgwick LLP

Seyfarth Shaw

Shearman & Sterling

Sidley Austin

Skadden

Sullivan & Cromwell

Trucker Huss

Weil Gotshal

COMPANIES

Altera Corporation

Amazon.com Inc.

Argentum Pharmaceuticals LLC

Bank of America Corporation

Briggs & Stratton Corporation

BuzzFeed Inc.

Competitive Enterprise Institute

Discover Financial Services

Duquesne Light Holdings Inc.

Fannie Mae

Financial Industry Regulatory Authority Inc.

Florida Bar Association

Freddie Mac

Goldman Sachs Group Inc.

JPMorgan Chase & Co.

Johnson & Johnson

McKinsey & Company

Nomura Holdings, Inc.

Oglethorpe Power Corp.

Purdue Pharma LP

Schlumberger Limited

State Farm

Sterling Jewelers Inc.

Susquehanna International Group LLP

The Bank of New York Mellon Corp.

The Royal Bank of Scotland Group PLC

Twitter Inc.

U.S. Bancorp

GOVERNMENT AGENCIES

California Department of Justice

Delaware Court of Chancery

European Commission

European Union

Executive Office of the President

Federal Energy Regulatory Commission

Federal Housing Finance Agency

Internal Revenue Service

Pennsylvania Supreme Court

U.S. Department of Justice

U.S. Department of the Treasury

U.S. Environmental Protection Agency

U.S. House of Representatives

U.S. Supreme Court