Return-Path: Received: from vps.transocean.com by vps.transocean.com with LMTP id mCM0M0GqZVp+KQAAInt2oQ ; Mon, 22 Jan 2018 01:09:21 -0800 Return-path: Envelope-to: bruce@transocean.com Delivery-date: Mon, 22 Jan 2018 01:09:21 -0800 Received: from o4.mailings-q.law360.com ([167.89.1.233]:62761) by vps.transocean.com with esmtps (TLSv1.2:ECDHE-RSA-AES128-GCM-SHA256:128) (Exim 4.89_1) (envelope-from ) id 1edY6K-0002jZ-O0 for bruce@transocean.com; Mon, 22 Jan 2018 01:09:21 -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=o3us1gTXk+GISO/7E7nKsYEcX84=; b=j5lzDz2UwEWnnS3vekUqpMg 8eTsG09UAFFTQrFID/LSf/LCV9Yzx9caU5a4HIWakAJYxREwUXo8ZJnJov8/fUQ0 bbvfNEGZD/A7boE77hif0+QnO0zJZciYmiM9uHSWI5c6ikXr9gEiz+MA96zN/WDj 65rKxV0zkmXN5hem7Em8= Received: by filter0449p1iad2.sendgrid.net with SMTP id filter0449p1iad2-11119-5A65AA0F-2 2018-01-22 09:08:31.312051352 +0000 UTC Received: from www.law360.com (ec2-54-157-200-102.compute-1.amazonaws.com [54.157.200.102]) by ismtpd0001p1iad1.sendgrid.net (SG) with ESMTP id 3E-x9ng-SSWSF4QnwlSvdA for ; Mon, 22 Jan 2018 09:08:31.094 +0000 (UTC) Date: Mon, 22 Jan 2018 09:08:31 +0000 (UTC) From: Tax Law360 To: bruce@transocean.com Message-ID: <5a65aa0fe0fc_15a12af555a10f486959cb@ip-172-30-200-105.mail> Subject: IRS Prepares For Gov't Shutdown As Filing Season Looms Mime-Version: 1.0 Content-Type: text/html; charset=UTF-8 Content-Transfer-Encoding: 7bit X-SG-EID: Opio7iv9VGQ4tDJiJszIh3zd7qYkeM6M7FLocQY/BAUEiZKe0LPPFxbegi2He4M0GNAHyjfr58pBKz DE5U6gjMiJyi96h0QH3bEqnpQmFVPRPel6C80d9YVrAMo3CxIJBwyzbakG7PN+Oyq+gf4/JvftWQyN mGWvc835aCUiyGrflek4lSOQECzVqj0kou3xOgoon1Q9M63qp6iOzAbFzw== 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: After Congress failed to reach a Friday night deadline to renew funding for the federal government, the IRS was set to put in place a contingency plan that would see the agency lose more than half of its workforce at the beginning of filing season and coming on the heels of the largest change to the tax code in 30 years. 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 RCVD_IN_MSPIKE_H4 RBL: Very Good reputation (+4) [167.89.1.233 listed in wl.mailspike.net] -0.0 SPF_PASS SPF: sender matches SPF record -0.0 T_RP_MATCHES_RCVD Envelope sender domain matches handover relay domain 0.8 BAYES_50 BODY: Bayes spam probability is 40 to 60% [score: 0.5000] 0.7 MIME_HTML_ONLY BODY: Message only has text/html MIME parts 0.0 HTML_MESSAGE BODY: HTML included in message 0.0 HTML_FONT_LOW_CONTRAST BODY: HTML font color similar or identical to background 0.1 DKIM_SIGNED Message has a DKIM or DK signature, not necessarily valid 0.0 LOTS_OF_MONEY Huge... sums of money 0.0 T_DKIM_INVALID DKIM-Signature header exists but is not valid -0.0 RCVD_IN_MSPIKE_WL Mailspike good senders X-Spam-Flag: NO
After Congress failed to reach a Friday night deadline to renew funding for the federal government, the IRS was set to put in place a contingency plan that would see the agency lose more than half of its workforce at the beginning of filing season and coming on the heels of the largest change to the tax code in 30 years.
Law360 Tax TAX
Monday, January 22, 2018 Follow Tax Law360
TOP NEWS

IRS Prepares For Gov't Shutdown As Filing Season Looms

After Congress failed to reach a Friday night deadline to renew funding for the federal government, the IRS was set to put in place a contingency plan that would see the agency lose more than half of its workforce at the beginning of filing season and coming on the heels of the largest change to the tax code in 30 years. Read more »

IRS Issues Guidance On Measuring Overseas Cash Earnings

The IRS issued a notice on Friday, fleshing out more details on how companies can calculate their overseas earnings when they bring them back to the United States under the recently enacted tax overhaul. Read more »

Analysis

No Proof Yet That Tax Cuts Have Boosted US Economy

The flood of bonuses and wage-increase announcements from retailers, banks and manufacturers can’t be held as a testament to the Republicans’ tax cuts, as analysts remain firm that these well-timed disclosures would have happened even without the recently passed tax legislation. Read more »

Immigration Standoff Keeps Government Shuttered

The Senate failed to reach a funding deal Sunday night, extending the government shutdown as both parties continued to clash over longstanding spending and immigration issues.  Read more »

Judiciary Can Stay Open For 3 Weeks After Shutdown

Even though the government has shut down, the federal courts will open their doors Monday and remain up and running at least until their funds run dry in about three weeks, an Administrative Office of U.S. Courts spokesperson said Friday. Read more »

FEDERAL

Mining Co.'s $19M Foreign Funds Taxable, 5th Circ. Affirms

The Fifth Circuit on Thursday affirmed a U.S. Tax Court ruling that $19 million of investor funds wired to the owner of a Texas mining company was taxable as income from a foreign company because the owner used much of the money for personal expenses.  Read more »

Texas Oil Driller Settles $618M IRS Dispute In Tax Court

The oil exploration unit of Texas-based Lewis Energy Group LP has reached a settlement with the IRS that will see the company recognize far less income for its 2011 tax year than the $618 million originally sought by the agency, according to a decision entered in the U.S. Tax Court Friday. Read more »

Gov't Seeks High Court Look At $75M Rail Co. Tax Refund

The IRS asked the U.S. Supreme Court on Thursday to reconsider an Eighth Circuit decision to award a railroad company a $75 million refund of taxes paid on employee stock options, but wants the court to put its petition on ice until it rules on a similar case. Read more »

US Chamber Pushes Gas Tax Hike In Infrastructure Blueprint

The U.S. Chamber of Commerce pitched an infrastructure investment plan Thursday calling for a 25-cent federal gas tax hike, more public-private partnerships and streamlined permitting processes, urging Congress and the Trump administration to advance a meaningful infrastructure bill this year. Read more »

NY Judge Denies Uber’s Proposed $3M Settlement

A New York federal judge on Friday denied preliminary approval for a proposed $3 million agreement to settle claims that Uber Technologies Inc. improperly accounted for taxes and other charges in calculating a service fee it deducted from fares earned by New York drivers. Read more »

'Jersey Shore' Star, Brother Plead Guilty To Tax Charges

Michael “The Situation” Sorrentino, a performer on the defunct reality TV series “Jersey Shore,” and his brother Marc Sorrentino copped to tax-related charges Friday in New Jersey federal court, with the television personality’s attorney later saying that he hopes to stay out of prison. Read more »

STATE & LOCAL

Analysis

High Court Signals Interest In Hearing 2nd State Tax Case

In the same week the U.S. Supreme Court shocked the tax bar by agreeing to hear the Wayfair case, the court strongly signaled it would consider taking on another state tax case in which federal law enforcement retirees challenge West Virginia's tax laws. Read more »

Texas Justices To Hear Wastewater Disposal Well Tax Fight

The Texas Supreme Court on Friday agreed to review a dispute between saltwater disposal well companies and the Parker County Appraisal District in which the companies argue that the district’s decision to tax their underground wastewater disposal wells separately from the surface constitutes unconstitutional double taxation. Read more »

Judge OKs $118M Philly Property Revaluation Challenge

A Pennsylvania judge gave the green light Friday to claims in a set of consolidated cases accusing the city of Philadelphia of violating constitutional principles of uniform taxation by singling out commercial and other classes of property for revaluations to raise $118 million in new revenue. Read more »

INTERNATIONAL

Transfer Price Change Can't Alter Customs Value: EU Court

German customs officials are not required to retroactively adjust the value of imported items based on changes made under a transfer pricing arrangement between a subsidiary in the country and its Japanese parent company, the European Union’s top court has ruled. Read more »

PEOPLE

Taxation With Representation: Wachtell, Kirkland, Latham

In this week’s Taxation With Representation, Silver Lake and P2 purchased Blackhawk for $3.5 billion, Energizer acquired Spectrum’s battery business for $2 billion, Wyndham snapped up La Quinta for $1.95 billion, and Energy Transfer sold its natural gas compression business to USA Compression for $1.8 billion. Read more »

EXPERT ANALYSIS

State Income Tax Implications Of Base-Broadening Reform

Components of the Tax Cuts and Jobs Act, P.L. 115-97, aimed at broadening the business tax base will significantly affect state income taxes because many states reference federal law in defining taxable income. States and corporate taxpayers have barely begun to grapple with a host of issues raised, say attorneys at McDermott Will & Emery LLP. Read more »

New Partnership Audit Regulations Shift IRS Focus

For the first time in 30 years, Congress has passed significant changes to partnership audit rules, enacting the Bipartisan Budget Act. Attorneys must prepare to advise their real estate clients on the best way to address these new rules, which focus on partnerships rather than individual partners, says Julia Turk of Much Shelist PC. Read more »

The Potential Impact Of Taxing Nondisclosure Agreements

Recent tax amendments no longer permit corporations to deduct sexual harassment settlements subject to nondisclosure agreements. However, these provisions will likely have a negligible effect on the number of agreements that are subject to disclosure, reduce the value of settlements paid to victims, and the increased taxes that result will be paid largely by victims of harassment, say Allan King and William Hays Weissman of Littler Mendelson PC. Read more »

Looking Back At The Life Settlements Industry In 2017

While 2017 was a relatively quiet year on the regulatory front for life settlements, Delaware and Florida adopted major legislative reforms that will affect the industry. Adjustments to the federal income tax code at the end of the year also brought some important changes, say Brian Casey and Thomas Sherman of Locke Lord LLP. Read more »

LEGAL INDUSTRY

Dentons Probing Claims Of Atty’s 'Inappropriate Behavior'

Dentons has put on leave one of the partners it absorbed in its October combination with Scottish firm Maclay Murray & Spens LLP while the firm investigates claims of “inappropriate behavior,” the firm confirmed Friday. Read more »

Analysis

How To Set Up A Legal Ops Function

A legal operations function is a significant behavioral change for a law department, and although there isn't a required rubric to follow when establishing one, getting buy-in from executives and the general counsel is crucial from the start. Read more »

Ex-Dewey Exec DiCarmine Might Represent Self At SEC Trial

Former Dewey & LeBoeuf LLP executive director Stephen DiCarmine is considering defending himself against the U.S. Securities and Exchange Commission's fraud claims at a possible jury trial because of "significant financial issues," his counsel told a Manhattan federal judge Friday. Read more »

GC Cheat Sheet: The Hottest Corporate News Of The Week

The Federal Communications Commission chairman prodded broadcasters to transmit Blue Alerts, Al Jazeera's former general counsel joined DLA Piper in Qatar and the U.S. Supreme Court declined to hear a trio of employment cases. These are some of the stories in corporate legal news you may have missed in the past week. Read more »

Podcast

Law360's Pro Say: Lawyer Sold You Out? Tell The Justices

On the latest episode of Law360's Pro Say podcast, the team discusses whether an attorney can go against the wishes of his client as part of trial strategy, cases filed against the rollback of net neutrality, two new big cases that the U.S. Supreme Court has agreed to hear, and a former "Jersey Shore" star who changed his signature GTL to “gym, tax evasion, laundry.” Read more »

In Case You Missed It: Hottest Firms And Stories On Law360

For those who missed out, here's a look back at the law firms, stories and expert analyses that generated the most buzz on Law360 last week. Read more »

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LAW FIRMS

Akerman

Chamberlain Hrdlicka

Covington & Burling

DLA Piper

Debevoise & Plimpton

Dentons

Dewey & LeBoeuf

Eversheds Sutherland

Gibson Dunn

Greenberg Traurig

Haynes and Boone

Held & Hines

Hogan Lovells

Jones Day

Kirkland & Ellis

Klehr Harrison

Knobbe Martens

Krovatin Klingeman

Latham & Watkins

Littler Mendelson

Locke Lord

Maclay Murray

Mayer Brown

McDermott Will

Meadows Collier

Mintz Levin

Morgan Lewis

Much Shelist

Nichols Jackson

O'Melveny & Myers

Ogletree Deakins

Paul Weiss

Quinn Emanuel

Reed Smith

Schiff Hardin

Sedgwick LLP

Skadden

Taft Stettinius

Vinson & Elkins

Wachtell Lipton

White and Williams

Wiley Rein

COMPANIES

AXA SA

Al Jazeera Media Network

American Federation of State, County and Municipal Employees

Apple Inc.

Association of Corporate Counsel

Blackhawk Network Holdings Inc.

Canadian National Railway Company

Citigroup Inc.

Energizer Holdings, Inc.

Energy Transfer Equity, L.P.

Energy Transfer Partners, L.P.

Facebook

Federation Internationale de Football Association

General Electric Company

General Motors

Google Inc.

Home Depot, Inc.

Lincoln National Corporation

Major Lindsey & Africa

Marriott International Inc.

MetLife Inc.

Moody's Corporation

National Association of Broadcasters

National Association of Insurance Commissioners

New York Times Co.

Public Knowledge

Silver Lake

Spectrum Brands, Inc.

Target Corporation

Transamerica Corp.

U.S. Bancorp

U.S. Chamber of Commerce

USA Compression Partners LP

Uber Technologies Inc.

Union Pacific Corporation

Wal-Mart Stores Inc.

Wayfair LLC

Wilmington Trust Corp.

Wyndham Worldwide Corporation

GOVERNMENT AGENCIES

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European Union

Federal Communications Commission

Internal Revenue Service

New York State Department of Financial Services

Pennsylvania Supreme Court

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U.S. Department of Justice

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