Tuesday, March 20, 2018

TOP NEWS

Treasury Urges 5th Circ. To Reinstate Anti-Inversion Rule

The U.S. Department of the Treasury urged the Fifth Circuit in an appeal filed Friday to resurrect a temporary rule invalidated by a Texas federal court after it sank a planned $160 billion merger between Pfizer Inc. and Irish counterpart Allergan PLC, saying that it had fulfilled its obligations in promulgating the rule. Read more »

ABA Tax Group Needs Guidance On Foreign Partnership Rules

The Internal Revenue Service needs to quickly clarify whether limits on the recognition of certain gains or losses apply to provisions in the new federal tax law that involve foreign investors in U.S. partnerships, the American Bar Association’s tax group said Monday. Read more »

Justices Refuse To Hear Pot Co.'s Challenge Of IRS Probe

The U.S. Supreme Court told a Colorado-based marijuana company on Monday that it would not hear its lawsuit against the Internal Revenue Service alleging the agency lacked authority to investigate criminal activity. Read more »

Justices Rebuff Bankrupt Manufacturer's Tax Penalty Appeal

The owner of a manufacturing company that declared bankruptcy 20 years ago must pay the Internal Revenue Service about $400,000 in penalties after the U.S. Supreme Court refused on Monday to entertain an appeal explaining why taxes had not been paid. Read more »

FBI Properly Withheld Trump's Tax Returns, DC Judge Says

A D.C. federal judge on Monday ruled against a journalist and a historian who sought information related to President Donald Trump’s tax returns, finding the FBI and Secret Service conducted an adequate search in response to their request and properly withheld records. Read more »

FEDERAL

Rank Can't Make Alcoa Pay $10M Chilean Tax, Judge Says

A New York federal judge ruled Monday that Alcoa Inc. shouldn’t have to foot a $10 million Chilean tax bill for Rank Group Ltd. following its $2.7 billion purchase of Alcoa’s packaging business, finding Rank incurred the tax by not paying off a loan it acquired in the deal. Read more »

UK Atty Tells Jury He Is Scapegoat For Tax-Cheating Heirs

British lawyer Michael Little told a Manhattan jury Monday he is the “scapegoat” for the family of deceased investor Harry Seggerman, defending himself against charges that he helped his client’s heirs dodge taxes on $14 million of inheritance money and dodged his own tax bills to boot. Read more »

1st Circ. Rejects Racial Argument, Upholds Fraud Sentences

A pair of grocery store employees face three-year prison terms after a First Circuit panel on Friday held race was not a factor behind the government rejecting a potential juror in a tax fraud case involving hundreds of bogus tax refunds and more than $2.6 million. Read more »

Tax Court Ruling ‘Absurd,’ Professors Tell 2nd Circ.

A U.S. Tax Court ruling denying a Connecticut woman's bid to reclaim her overpayment in a case of first impression led to an “absurd” result and must be overturned, according to an amicus brief filed in the Second Circuit Friday by two tax professors. Read more »

STATE & LOCAL

Taxation Group Opposes Daily Sales Tax Settlement In Mass.

The Council on State Taxation has joined the protest against a bill in Massachusetts that would require retailers and credit card processors to submit daily sales tax receipts, arguing the measure would be costly to administer and harmful to business and would offer no financial gain. Read more »

INTERNATIONAL

ECJ Rules French Proprietor Owes Tax Despite Swiss Move

A businessman still owes capital gains tax on his holdings despite moving from France to Switzerland, the European Court of Justice ruled, finding that the agreement allowing for free movement between the European Union and Switzerland did not apply or supersede French law. Read more »

Rio Tinto Nears Arbitration Over $155M Mongolian Tax Bill

Mining company Rio Tinto and Mongolia could be headed for international arbitration after the company's Canadian subsidiary filed a formal notice of dispute regarding the valuation of a copper mine on the southeastern border, a move that gives the parties several months to resolve the country's recent claim that it's owed $155 million in back taxes. Read more »

EU Gears Up To Retaliate Against US Steel, Aluminum Tariffs

The European Commission is seeking input from “private stakeholders” regarding increased tariffs it may impose on goods imported from the United States in the wake of an order signed by President Donald Trump earlier this month imposing controversial tariffs on imports of steel and aluminum. Read more »

EXPERT ANALYSIS

A View From Silicon Valley: Tax Reform And The Tech Industry

Many of the most discussed provisions in the Tax Cuts and Jobs Act have particular significance for the technology industry, affecting companies’ choices about entity classification, where they do business and hold assets, and the manner in which they receive or make investments. Michele Alexander and Ryan Davis of Bracewell LLP discuss the options. Read more »

LEGAL INDUSTRY

Feature

How Female GCs Help Women Advance Their Law Careers

At the beginning of her career, Helen Browne said she wasn't allowed to wear pants and colleagues often questioned her employment since she was married to a working man. Now, as group general counsel of French multinational insurance firm AXA, she said it's hard to believe how much has changed. Here, Browne and other female GCs share how they're transforming their departments and other women's professional lives. Read more »

Analysis

15 Minutes With PayPal’s General Counsel

Shortly after she joined PayPal in 2015, Wanji Walcott initiated her second pro bono program in the corporate legal realm, this time across the world. Here, the online payment company’s general counsel and senior vice president discusses with Law360 how she explains complicated legal matters to nonlawyers and which book she recommends to attorneys hoping to enhance their craft. Read more »

White & Case Reports 24% Gender Pay Gap In London

White & Case LLP became the first U.S. law firm on Monday to report its gender pay gap data to the U.K. government under a new law, revealing a 24 percent divide between what the average man and average woman earns in its London office. Read more »

Akin Gump Reps Tippee Pro Bono In Insider Trading Case

Akin Gump Strauss Hauer & Feld LLP has agreed to take up the defense of a computer analyst charged with trading on confidential merger information gleaned from a former Bank of America executive pro bono, according to notices filed Friday in New York federal court. Read more »

Judge OKs Eagan Avenatti's Exit From Ch. 11

A California bankruptcy judge has approved a settlement ending the bankruptcy of defunct class action law firm Eagan Avenatti LLP — owned by the attorney representing Stormy Daniels in her legal battle against President Donald Trump — that allows a former partner to collect $4.85 million to resolve his claims of allegedly unpaid fees. Read more »

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