Return-Path: Received: from vps.transocean.com by vps.transocean.com with LMTP id sKiSIydAploBTQAAInt2oQ ; Mon, 12 Mar 2018 01:53:59 -0700 Return-path: Envelope-to: bruce@transocean.com Delivery-date: Mon, 12 Mar 2018 01:53:59 -0700 Received: from o4.mailings-q.law360.com ([167.89.1.233]:28663) by vps.transocean.com with esmtps (TLSv1.2:ECDHE-RSA-AES128-GCM-SHA256:128) (Exim 4.89_1) (envelope-from ) id 1evJDG-00059c-6H for bruce@transocean.com; Mon, 12 Mar 2018 01:53:59 -0700 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=rNvmmD75C3+Ng0J+8GL4v8RxaNY=; b=yRVpoqMvavPABB5r20UJEZo FCOrdYwSWSzU1DXMvhARuyttC8ieTimV3KDcPNu+/1FmrY94p8rol/qVWRzXsMEL bkq6+7gQ9esq9crFr6pfJfIiwxVs4Dw2AV0cSZXQ7hAge8NNs5RLVeMzGx9QBfke cX1eNyHqFOwAZl6Cukpo= Received: by filter1109p1mdw1.sendgrid.net with SMTP id filter1109p1mdw1-23245-5AA63FF1-12 2018-03-12 08:53:05.950786078 +0000 UTC Received: from www.law360.com (ec2-54-236-22-224.compute-1.amazonaws.com [54.236.22.224]) by ismtpd0036p1mdw1.sendgrid.net (SG) with ESMTP id MsTEQmwiSSGTryaXNYGrqQ for ; Mon, 12 Mar 2018 08:53:05.833 +0000 (UTC) Date: Mon, 12 Mar 2018 08:53:06 +0000 (UTC) From: Tax Law360 To: bruce@transocean.com Message-ID: <5aa63ff19f89a_203a2b1749a3ef5465346e@ip-172-30-200-100.mail> Mime-Version: 1.0 Content-Type: text/html; charset=UTF-8 Content-Transfer-Encoding: quoted-printable X-SG-EID: Opio7iv9VGQ4tDJiJszIh3zd7qYkeM6M7FLocQY/BAVHqEuK1/Gssp735S6EuH00EC+6yy71fv0CvR z0TbPF55iFR/Gj9ERdHBIXgkpID967AAVKwv6y6ussK/PODKL2x1Q4FLLTNBf/S4J45799Tbq2iYV/ d+hKXxYV62m7v7atokhoJGR+jWZkqtiw4mKNJpnCyPNzhehfeJz+XuhxkA== X-Spam-Status: Yes, score=3.5 X-Spam-Score: 35 X-Spam-Bar: +++ X-Spam-Report: Spam detection software, running on the system "vps.transocean.com", has identified this incoming email as possible 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: Although President Donald Trump set a record with the number of circuit judges he named during his first year, experts say that's not the whole story. Here’s our data-driven look at what the White House faces in its quest to reshape the appeals courts. TAX [...] Content analysis details: (3.5 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: cloudfront.net] 1.3 RCVD_IN_BL_SPAMCOP_NET RBL: Received via a relay in bl.spamcop.net [Blocked - see ] -0.0 SPF_PASS SPF: sender matches SPF record -0.0 T_RP_MATCHES_RCVD Envelope sender domain matches handover relay domain 0.5 URI_NOVOWEL URI: URI hostname has long non-vowel sequence 0.0 HTML_MESSAGE BODY: HTML included in message 0.0 HTML_FONT_LOW_CONTRAST BODY: HTML font color similar or identical to background 0.8 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 0.1 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 X-Spam-Flag: YES Subject: ****SPAM**** How Far Right Can The President Pull The Courts?
Although President Donald Trump set a record with the number of circuit j= udges he named during his first year, experts say that's not the whole = story. Here=E2=80=99s our data-driven look at what the White House faces in= its quest to reshape the appeals courts.
3D"Law360 TAX
Monday, March 12, 2018 3D"Follow
IN-DEPTH
=09=09=09=09=09=09=09=09=09=09 3D"414"

Feature

=09=09=09=09

How Far Right Can The Presi= dent Pull The Courts?

Although President Donald Trump set a record with the number of circu= it judges he named during his first year, experts say that's not the whole = story. Here’s our data-driven look at what the White House faces in i= ts quest to reshape the appeals courts. Read more »

News Analysis

=09=09=09=09

Senior Judges Fill The= Void Left By Rampant Vacancies

More federal judges are skipping the golf course to head back to the = courtroom upon taking senior status, and they're playing an increasingly vi= tal role in a strained system. Read more »

News Analysis

=09=09=09=09

Why The ‘Blue Slip&#= 8217; Battles Are Becoming White Hot 3D=

It’s more of a norm than a rule. Its use has shifted over time,= often with political winds. But the once-obscure Senate tradition is now f= ront and center in the boiling debate over the future of the judiciary.=20= =20 Read more »

Op-Ed

=09=09=09=09

Grassley, Feinstein= Debate Judicial Vetting, Obstruction

It is undisputed that in his first year in office President Trump was= able to confirm a significant number of judges to the federal bench. How i= t happened — and whether it's a good thing — are debated here b= y Sen. Chuck Grassley, R-Iowa, and Sen. Dianne Feinstein, D-Calif. Read more »

TOP NEWS
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09

Weekly Column

SALT: Still Crazy After All These Yea= rs

While South Dakota v. Wayfair has reignited the love Quill, hate Quil= l, save Quill, kill Quill saga on the public stage, it is far from the only= tax dispute worth following. From baseball to lonesome income with no tax = home, Quarles & Brady LLP partner David Brunori breaks down the most notewo= rthy ongoing state and local tax controversies.=20 Read more »

=09=09=09=09 =09=09=09=09

‘Tax Extender= ’ Process Must Change, Congress Staffers Say

Congress must get off the merry-go-round of renewing targeted tax ben= efits every year or two because it makes for bad policy and increases uncer= tainty for businesses, staffers for the U.S. House and Senate tax committee= s said Friday. Read more »

=09=09=09=09 =09=09=09=09

5th Circ. Says Taxpayer= s Can't Extend Appeal Deadline

The Fifth Circuit refused to hear an appeal from two taxpayers unhapp= y with a U.S. Tax Court decision, saying that their repeat attempts to vaca= te that decision cannot extend their appeal deadline. Read more »

=09=09=09=09

Analysis

Alternative Ways To= Pay For Trump’s Infrastructure Plan

The Trump administration’s and certain lawmakers’ recent = willingness to discuss a federal gas tax hike to fund highway and other sur= face transportation upgrades spurs optimism that infrastructure funding is = high on the legislative agenda, but experts say there’s little chance= such a drastic policy shift will take flight this year. Read more »

=09=09=09=09 =09=09=09=09

Disputing Proposed Tax Reg= s Is Growing, Panel Says

Challenging proposed tax regulations before they are enforced is a gr= owing legal strategy that may give the bar a new way to represent clients, = attorneys said during a panel discussion Friday at a Federal Bar Associatio= n meeting. Read more »

FEDERAL
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09 =09=09=09=09

Fed. Circ. Affirms = Denial Of Couple's Tax Refund Lawsuit

The Federal Circuit on Friday upheld a lower court’s decision t= o dismiss a tax refund lawsuit as untimely in the case of a couple whom the= Internal Revenue Service found to have improperly applied passive activity= deductions and credits against nonpassive income. Read more »

=09=09=09=09 =09=09=09=09

IRS, Howard Stern S= hake Most Of Suit Over Aired Tax Call

A Massachusetts federal judge on Friday axed the bulk of a suit broug= ht by a woman whose private tax return information disclosed during a conve= rsation with an Internal Revenue Service agent was broadcast without her kn= owledge on Howard Stern's radio show, ruling that the IRS had broad immunit= y from her claims and that the radio show hadn't intentionally invaded her = privacy. Read more »

=09=09=09=09 =09=09=09=09

Tax Court Judge Trims = Coke's Evidence In $3.3B IRS Row

A U.S. Tax Court Judge on Friday struck down portions of an expert re= port submitted by The Coca-Cola Co. in the company's $3.3 billion transfer = pricing dispute with the Internal Revenue Service, after the government com= plained the interviews used to compile the report had not been properly doc= umented. Read more »

=09=09=09=09 =09=09=09=09

Import-Export Claus= e Needs High Court Review, County Says

A 70-year-old U.S. Supreme Court precedent for determining whether ta= xes on goods in transit violate the U.S. Constitution’s import-export= clause warrants another look due to inconsistent interpretations, a Virgin= ia county told the justices in a brief on Thursday. Read more »

=09=09=09=09 =09=09=09=09

Firm's Suit Over= Fees In Novartis Row Paused Over Atty Exit

A New Jersey federal judge on Thursday temporarily halted a law firm&= #8217;s case seeking payment from a former client who brought an unsuccessf= ul whistleblower suit accusing Novartis AG of tax improprieties, ordering t= he case adjourned for two months so the client can find new counsel. Read more »

=09=09=09=09 =09=09=09=09

Mass. Seafood Co. Manage= r Avoids Jail For Tax Evasion

The former manager of a Massachusetts-based seafood processor avoided= jail time on Friday after admitting he failed to report about $80,000 he n= etted, and will instead face home confinement, probation, and as many Uber = rides as it takes to pay back the government. Read more »

STATE & LOCAL
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09

Analysis

15 Months In, = Philly Still Plagued With Soda Tax Uncertainties

It’s been 15 months since the city of Philadelphia enacted its = sweetened beverage tax, and there looks to be no end in sight to the fighti= ng and fallout that have plagued it from the outset, thanks to lower-t= han-expected tax revenue as well as court battles. Read more »

=09=09=09=09 =09=09=09=09

Calif. Appeals Cour= t Affirms Automatic Tips Are Taxable

A California appellate court affirmed a trial court’s decision = Friday, saying that gratuities automatically imposed on restaurant checks f= or large groups are taxable, rejecting the claims made by an operator of mu= ltiple restaurants that such additions to checks were optional and legally = not subject to sales tax. Read more »

=09=09=09=09 =09=09=09=09

Mass. Gov's $610M Bill Ex= tends Fantasy Sports Gaming

Massachusetts Gov. Charlie Baker released a new economic development = framework and legislation Friday that commits $610 million to various infra= structure projects and will allow fantasy sports gaming to continue in the = state through the July deadline. Read more »

INTERNATIONAL
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09 =09=09=09=09

OECD Issues New Mod= el Disclosure Rules For Tax Advisers

The Organization for Economic Cooperation and Development on Friday f= inalized recommended rules that would require lawyers, accountants and othe= r tax advisers to disclose if they are marketing structures designed to avo= id new global reporting requirements that seek to curb tax avoidance.   Read more »

=09=09=09=09 =09=09=09=09

EU Probes UK 'Zero VAT' T= ax On Commodity Derivatives

The European Commission is investigating whether the British governme= nt is infringing European law over the way it taxes some commodity derivati= ves when they are traded on an exchange, HM Treasury said on Friday. Read more »

=09=09=09=09 =09=09=09=09

Use Mediation To P= romote Tax Arbitration, UN Official Says

More needs to be done to build confidence in mandatory binding arbitr= ation for tax treaties rather than just depending on external pressures to = continue its use, and having nonbinding third-party mediation may be the an= swer, a United Nations official said on Friday. Read more »

PEOPLE
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09 =09=09=09=09

Taxation With Representa= tion: Wachtell, Skadden, Baker

In this week’s Taxation with Representation, Cigna bought Expre= ss Scripts for $67 billion, GTCR LLC and Sycamore Partners took CommerceHub= private in a $1.1 billion deal and AXA Group acquired XL Group Ltd. for $1= 5.3 billion. Read more »

EXPERT ANALYSIS
=09=09=09=09=09=09=09=09=09= =09
=09=09=09=09 =09=09=09=09

How Settling With = The Gov't Is Costlier Under New Tax Law

A provision in the Tax Cuts and Jobs Act greatly expands the scope of= the disallowance of deductions for fines and penalties paid to government = agencies. This will make it costlier for a company to settle claims of viol= ation of laws and regulations brought by federal, state or local agencies, = or even foreign governments, says Marvin Kirsner of Greenberg Traurig LLP. Read more »

=09=09=09=09 =09=09=09=09

Tax Reform Complicates Middle-Ma= rket CLOs

The Tax Cuts and Jobs Act is causing concerns for advisers of middle-= market collateralized loan obligation issuers as it potentially imposes new= requirements. Advisers to MM CLOs must be creative and thoughtful in mitig= ating the potential adverse effects of Section 1446(f), say attorneys with = Cadwalader Wickersham & Taft LLP. Read more »

LEGAL INDUSTRY
=09=09=09=09=09=09=09=09=09=09
=09=09=09=09=09 =09=09=09=09=09

How Law Firms Can Be M= ore Efficient And Drive Profit

The average lawyer spends approximately two-thirds of their day on n= onbillable tasks, a bleak picture of efficiency in today’s law firms = offered up Friday by a speaker at the American Bar Association TechShow in = Chicago. Read more »

=09=09=09=09=09 =09=09=09=09=09

Legal Sector'= s Slow Year Continues With 200 Jobs Lost In Feb.

The U.S. legal sector continued its less-than-stellar start to 2018,= dropping another 200 jobs in February for the worst two-month stretch to b= egin a year since 2013, the Bureau of Labor Statistics reported Friday. Read more »

=09=09=09=09=09 =09=09=09=09=09

GC Cheat Sheet: The= Hottest Corporate News Of The Week

A new study from the United Kingdom found that men and women signifi= cantly differ on their perceptions of progress on gender equality in the le= gal industry, ​some companies continued to weigh whether to join the = growing crackdown of gun sales in the wake of last month’s Florida sc= hool shooting and panelists at a conference in Chicago addressed how to han= dle a lawyer who is cognitively impaired. These are some of the stories in = corporate legal news you may have missed in the past week.​ Read more »

=09=09=09=09=09

Podcast

Law360’s Pro Say= : Trump Looks To Transform The Courts

On the latest episode of Law360's Pro Say podcast, we examine the Tr= ump administration’s efforts to push the judicial branch to the right= , discuss Trump’s controversial trade moves, and explain how “i= nclusion riders” work. Read more »

=09=09=09=09=09 =09=09=09=09=09

In Case You Misse= d It: Hottest Firms And Stories On Law360

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

JOBS
Search full listings or advertise your job opening=09=09=09
3D"Law360

Listen to our new p= odcast here

LAW FIRMS

Akin Gump

Andres & Berger

Baker Botts

Barclay Damon

Begelman Orlow

Boies Schiller

Cadwalader Wickersham

Cohen & Gresser

Cohen Milstein

Covington & Burling

Cozen O'Connor

Crowe & Dunlevy

Greenberg Traurig

Hangley Aronchick

Hinshaw & Culbertson

Horwood Marcus

Marshall Dennehey

Mayer Brown

McGuireWoods

Miller & Chevalier

Morgan Lewis

Morrison & Foerster

Nossaman LLP

Ogletree Deakins

Orrick Herrington

Partridge Snow

Pate & Johnson

Quarles & Brady

Rose Law Firm

Skadden

Steptoe & Johnson LLP<= /p>

Troutman Sanders

Wachtell Lipton

COMPANIES

AXA SA

Allergan PLC

Altera Corporation

Amazon.com Inc.

American Bar Associ= ation

American Beverag= e Association

American Express Co= mpany

American Tr= ucking Associations Inc.

Brattle Group

Burson-Marsteller Inc.

Cigna Corporation

Cincinnati Reds

Commerce Technologi= es Inc.

Council on Foundations<= /a>

Delta Air Lines Inc.

Dick's Sporting= Goods Inc.

Dominion Energy Inc.

Express Scripts, Inc.<= /p>

Federal Bar Associatio= n

Federalist Society

Fitch Ratings Ltd.

Florida Banker= s Association Inc.

GTCR LLC

Google Inc.

Hertz Global Holdin= gs Inc.

Hulu LLC

Kroger Co.

L.L. Bean Inc.

MetLife Inc.

Morgan Stanley

NFL Enterprises LLC

National= Rifle Association of America

Netflix Inc.

New York State = Bar Association

Northeastern Universit= y

Novartis AG

Oil States Intern= ational Inc.

PepsiCo Inc.

Red Lobster Hospit= ality LLC

Renaissance Capital

Staples Inc.

Sycamore Part= ners Management LLC

Tax Foundation

The Coca-Cola Company

Twitter Inc.

U.S. Chamber of Commer= ce

Uber Technologies Inc.

United Contine= ntal Holdings Inc.

Wal-Mart Stores Inc.

Wayfair LLC

Wynn Resorts Ltd.

XL Catlin

GOVERNMENT = AGENCIES

Bureau of Labor Sta= tistics

Colorado = Department of Transportation

Consumer F= inancial Protection Bureau

European Commission

Executive Off= ice of the President

Federal Bureau = of Investigation

Federal Judicial Center=

Georgia Departmen= t of Revenue

Internal Revenue Servi= ce

NATO

New York State Comp= troller

Ohio Supreme Court

Oregon Legislature

Pennsylvania Suprem= e Court

Small Business Ad= ministration

U.S. Department of = Justice

U.S. Department of Labo= r

U.S. Department = of the Treasury

U.S. Patent and= Trademark Office

U.S. Senate

U.S. Supreme Court

United Nations

Wage and Hour Division
 

 

LAW FIRMS

Akin Gu= mp

= Miller & Chevalier

And= res & Berger

Baker= Botts

Bar= clay Damon

Be= gelman Orlow

Bo= ies Schiller

Cadwalader Wickersham

Coh= en & Gresser

Co= hen Milstein

Covington & Burling

Co= zen O'Connor

Cro= we & Dunlevy

Greenberg Traurig

Hangley Aronchick

Hinshaw & Culbertson

Ho= rwood Marcus

Marshall Dennehey

Mayer= Brown

McGu= ireWoods

Morg= an Lewis

Morrison & Foerster

Noss= aman LLP

= Ogletree Deakins

Orrick Herrington

Pa= rtridge Snow

Pate= & Johnson

Qua= rles & Brady

Ros= e Law Firm

Skadden

Steptoe & Johnson LLP

= Troutman Sanders

W= achtell Lipton
 
COMPANIES

American Bar Association

Delta Air Lines Inc.

Federal Bar Association

National Rifle Association of America

T= witter Inc.

AXA SA=

= Allergan PLC

Altera Corporation

Amazon.com Inc.

American Beverage Association

American Express Company

American Trucking Associations Inc.

Brattle Group

Burson-Marsteller Inc.

Cigna Corporation

Cincinnati Reds

Commerce Technologies Inc.

Council on Foundations

Dick's Sporting Goods Inc.

Dominion Energy Inc.

Express Scripts, Inc.

Federalist Society

Fitch Ratings Ltd.

Florida Bankers Association Inc.

GTCR= LLC

Go= ogle Inc.

Hertz Global Holdings Inc.

Hulu= LLC

Kro= ger Co.

= L.L. Bean Inc.

M= etLife Inc.

Morgan Stanley

NFL Enterprises LLC

N= etflix Inc.

New York State Bar Association

Northeastern University

N= ovartis AG

Oil States International Inc.

P= epsiCo Inc.

Red Lobster Hospitality LLC

Renaissance Capital

S= taples Inc.

Sycamore Partners Management LLC

Tax Foundation

The Coca-Cola Company

U.S. Chamber of Commerce

Uber Technologies Inc.

United Continental Holdings Inc.

Wal-Mart Stores Inc.

W= ayfair LLC

Wynn Resorts Ltd.

XL = Catlin
 
GOVERNMENT AGENCIES

Internal Revenue Service

U.S. Department of Justice

U.S. Supreme Court

United Nations

Bureau of Labor Statistics

Colorado Department of Transportation

Consumer Financial Protection Bureau

European Commission

Executive Office of the President

Federal Bureau of Investigation

Federal Judicial Center

Georgia Department of Revenue

NATO<= /p>

New York State Comptroller

Ohio Supreme Court

Oregon Legislature

Pennsylvania Supreme Court

Small Business Administration

U.S. Department of Labor

U.S. Department of the Treasury

U.S. Patent and Trademark Office

U.S= . Senate

Wage and Hour Division
 

JOBS
Search full listings or advertise your job opening=09=09=09

 

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