Return-Path: Received: from vps.transocean.com by vps.transocean.com with LMTP id wDSpIL2Hjlr3dAAAInt2oQ ; Thu, 22 Feb 2018 01:05:01 -0800 Return-path: Envelope-to: bruce@transocean.com Delivery-date: Thu, 22 Feb 2018 01:05:01 -0800 Received: from o4.mailings-q.law360.com ([167.89.1.233]:45477) by vps.transocean.com with esmtps (TLSv1.2:ECDHE-RSA-AES128-GCM-SHA256:128) (Exim 4.89_1) (envelope-from ) id 1eomo8-0007m9-KY for bruce@transocean.com; Thu, 22 Feb 2018 01:05:01 -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=hqxx5EeY4xIUD9H16m0LaAZST1o=; b=S/K3aL1gmWHGRNCnrjkBrHu 76RV4KOY0qwrNDwpRCY022ykdNatPocsf1y5Y5Z97O8py6LbOPWVYB9A8dzktEy2 z+kz7QLB2Nzcmh61qr9zOb7U9JJUxY/fnrWxE6bQ9z5rku4LbTQUjUuJHEPB35gK VXOdlMYJNa31poj5mY48= Received: by filter0130p1iad2.sendgrid.net with SMTP id filter0130p1iad2-31299-5A8E878B-3 2018-02-22 09:04:11.176118235 +0000 UTC Received: from www.law360.com (ec2-34-201-103-27.compute-1.amazonaws.com [34.201.103.27]) by ismtpd0007p1iad2.sendgrid.net (SG) with ESMTP id 9nxnVtM8T3S734gU-fx6kA for ; Thu, 22 Feb 2018 09:04:11.156 +0000 (UTC) Date: Thu, 22 Feb 2018 09:04:11 +0000 (UTC) From: Tax Law360 To: bruce@transocean.com Message-ID: <5a8e878b17858_75d82b0a583fef5c66345d@ip-172-30-200-145.mail> Subject: Feds Can't Get Israeli Court Info In $163M Perrigo Tax Row Mime-Version: 1.0 Content-Type: text/html; charset=UTF-8 Content-Transfer-Encoding: 7bit X-SG-EID: Opio7iv9VGQ4tDJiJszIh3zd7qYkeM6M7FLocQY/BAUjJQmuqcPPtRuiiHUBgkzoJWUmnHFrIHT+AI EXWxbuTO7Pl7m3jgHRMUZhCJlIQPqDgXHigM/ejSp9297hlnS4k38veRCj7IrZkFLEt0TGmujbq8WU bQiIgSHOd3Ve7ZwycB5zgZk2opks4YLNkEQldLDsZx7c9d+p4LZ3FpSD+g== 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: A Michigan federal judge refused on Wednesday to ask Israeli courts for information the U.S. government is seeking in a $163.5 million tax fight against a company that domestically distributed heartburn drugs manufactured in Israel in partnership with Perrigo Co., saying such requests would unnecessarily add to the time, cost and complexity of the case. 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 T_RP_MATCHES_RCVD Envelope sender domain matches handover relay domain -0.0 SPF_PASS SPF: sender matches SPF record 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_FONT_LOW_CONTRAST BODY: HTML font color similar or identical to background 0.0 HTML_MESSAGE BODY: HTML included in message 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 RCVD_IN_MSPIKE_WL Mailspike good senders 0.0 T_DKIM_INVALID DKIM-Signature header exists but is not valid X-Spam-Flag: NO
A Michigan federal judge refused on Wednesday to ask Israeli courts for information the U.S. government is seeking in a $163.5 million tax fight against a company that domestically distributed heartburn drugs manufactured in Israel in partnership with Perrigo Co., saying such requests would unnecessarily add to the time, cost and complexity of the case.
Law360 Tax TAX
Thursday, February 22, 2018 Follow Tax Law360
TOP NEWS

Feds Can't Get Israeli Court Info In $163M Perrigo Tax Row

A Michigan federal judge refused on Wednesday to ask Israeli courts for information the U.S. government is seeking in a $163.5 million tax fight against a company that domestically distributed heartburn drugs manufactured in Israel in partnership with Perrigo Co., saying such requests would unnecessarily add to the time, cost and complexity of the case. Read more »

NJ Trader Faces New Charges In Market Manipulation Case

A New Jersey-based trader was hit with additional charges Wednesday over an alleged market manipulation scheme that raked in millions over a two-year period, according to authorities. Read more »

Dems Could Have Kept SALT In TCJA, Senate Counsel Says

A senior tax counsel on the Senate Finance Committee said Wednesday if Democrats had taken part in crafting the new federal tax law, it likely would have led to a different outcome for the $10,000 deduction limit for state and local taxes that many blue states continue to fight against or try to work around. Read more »

NY Tax Atty Charged With Tax Fraud Over $3.5M Charity Scam

Federal prosecutors on Wednesday slapped the head of Manhattan-based Sadis & Goldberg LLP’s tax and trusts and estates groups with criminal tax fraud charges, saying the lawyer bilked a dead client’s estate for more than $3.5 million through a bogus charity and lied about his true income to the IRS. Read more »

FEDERAL

Tax Court Rejects Religious Nonprofit's Bid For Costs

The U.S. Tax Court on Wednesday declined to award about $69,000 to a religious group for its costs to petition the IRS for nonprofit status, ruling that the group did not seek proper administrative costs and that the IRS did not act unjustly in responding to the group's petition after the group went to court. Read more »

Okla. Tribe Asks 10th Circ. To Rethink $27M Tax Ruling

The Citizen Potawatomi Nation urged the Tenth Circuit on Tuesday to revisit its ruling vacating an arbitration decision that had exempted the tribe from $27 million in alcohol sales taxes, saying the court wrongly struck down the arbitration provision in the tribe’s gambling deal with the state. Read more »

Publisher's $2M Refund Claim Came Too Late, 2nd Circ. Told

The government asked the Second Circuit on Tuesday to affirm a New York federal court's dismissal of a $2.1 million tax refund suit by the publisher of Reader's Digest, saying the company’s request for a refund came too late. Read more »

Jackson Hewitt Faces Franchisee Customer's Fraud Claims

Tax preparation chain Jackson Hewitt must face putative class allegations of fraud and negligence after a California federal judge ruled Tuesday that a former client of a franchisee had presented a plausible theory for his claims to proceed in court. Read more »

Aviation Contractor Seeks Rival's Tax Docs In $4.6M Row

A former subsidiary of aviation defense contractor AAL Group urged an Alabama federal court Tuesday to compel Black Hall Aerospace to turn over tax documents it says are relevant to its claims that the aerospace company owes it more than $4.6 million. Read more »

Pa. Man Gets 1 Year For Aiding Tobacco Tax Evasion

A Pennsylvania distributor was sentenced to a year and a day behind bars in Massachusetts federal court Wednesday after pleading guilty to helping a Bay State wholesaler avoid paying more than $9.6 million in taxes on massive shipments of tobacco products. Read more »

INTERNATIONAL

Dutch Official Says Tax Rulings Must Retain Certainty Aspect

A Dutch tax official, in announcing changes to the country's program for administering advance pricing agreements and other tax rulings, has stressed the importance of continuing to allow settlement of tax cases at an early stage, saying certainty has always been a pillar of the advance rulings process. Read more »

Carbon-Related Tax Unlikely Under Int'l Rules, Prof Says

A border-adjusted tax aimed at imports with large carbon footprints could theoretically comply with World Trade Organization rules, but mandates requiring consistent treatment of items from different countries could make the policy difficult to carry out in reality, a law professor said at a conference in Houston on Wednesday. Read more »

UK Tax Policy Reflects Maturing Oil Fields, Official Says

A recently introduced U.K. policy that would allow energy companies to transfer corporate tax histories was designed to reflect the fact that large companies are selling off mature oil fields to smaller players that have less financial backing, an HM Treasury official said Wednesday. Read more »

EXPERT ANALYSIS

How Tax Reform Changes The Treatment Of Fringe Benefits

The Tax Cuts and Jobs Act significantly changed the federal taxation of fringe benefits. With the elimination or reduction of deductions for employers, elimination of employee exemptions and other changes, reform's treatment of fringe benefits promises a ripple effect reaching many aspects of employee compensation, say attorneys at Morgan Lewis & Bockius LLP. Read more »

LEGAL INDUSTRY

Feature

Why BigLaw Firms Are Hungry To Enter And Grow In Dallas

The desire of large law firms to set up shop and grow in Dallas appears to have reached near-frenzy levels, with reports of new offices springing up, mergers being inked, and fierce competition in the lateral market replete with hefty paychecks. Read more »

Andrews Kurth, Hunton & Williams Will Combine In April

After months of rumors and negotiations, the merger between Texas-based Andrews Kurth Kenyon LLP and Virginia's Hunton & Williams LLP has been resoundingly approved by partner votes at both firms, and the union is on track to completion by the end of the quarter, the firms announced Wednesday. Read more »

LA-Based Ogletree Shareholder Sued For Sexual Harassment

Less than six weeks after being hit with a $300 million gender discrimination class action, labor and employment law firm Ogletree Deakins Nash Smoak & Stewart PC was accused Wednesday in a California state suit of allowing one of its Los Angeles shareholders to sexually harass a married, gay, Latino attorney. Read more »

Baker McKenzie Taps UK Firm For Sexual Assault Inquiry

Baker McKenzie has engaged London-based international firm Simmons & Simmons to perform an independent inquiry into a years-old sexual assault complaint and the firm’s initial response to it, a spokesperson confirmed Wednesday. Read more »

Judiciary Collecting Sexual Harassment Data

In the wake of the scandal surrounding former Ninth Circuit Judge Alex Kozinski, the federal judiciary is tracking and releasing sexual harassment complaint data, the Administrative Office of the U.S. Courts announced on its website Wednesday. Read more »

Analysis

Latest Russia Plea A Glimpse Into Mueller’s Universe

The former Skadden Arps Slate Meagher & Flom LLP lawyer who pled guilty to lying to investigators Tuesday offered a peek into the evidence that special counsel Robert Mueller has developed, experts said, and sent a powerful warning to anyone who might lie to investigators. Read more »

Series

What I Learned In My 1st Year: Working For Uncle Wally

My uncle asked me to research some point of law. I left his office to collect my thoughts, then went back in and asked him a question or two. He looked up and gave me his six-word answer: “Do I look like a library?” He taught me that there are no shortcuts to doing your job, says Paul Hamburger of Proskauer Rose LLP. Read more »

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