The Internal Revenue Service=E2=80=99s recent interim guidance on the new= tax law=E2=80=99s requirement to withhold tax on foreign partnership trans= fers is largely prospective and is raising questions about whether and how = to withhold in transactions that have already taken place this year.

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Wednesday, April 11, 2018

TOP NEWS

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=09=09=09=09

Analysis

Withholding Rules= For Foreign Partnership Sales Still Hazy

The Internal Revenue Service’s recent interim guidance on the n= ew tax law’s requirement to withhold tax on foreign partnership trans= fers is largely prospective and is raising questions about whether and how = to withhold in transactions that have already taken place this year. Read more »

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

IRS Overhaul Bills Mak= e Greater Cybersecurity A Focus

Lawmakers pushed for greater cybersecurity at the Internal Revenue Se= rvice on Tuesday as part of a series of bills, introduced in the House= of Representatives, that are intended to reconfigure the agency. Read more »

=09=09=09=09

Analysis

In High Court Onli= ne Tax Case, Handicappers See Win For SD

The U.S. Supreme Court is likely to hand South Dakota a victory in th= e state’s quest to compel remote retailers to collect and remit use t= ax, a ruling that would upend decades of practice in state taxation, expert= s say. Read more »

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

Treasury Finalizes Rule= For IRS Contracting Officers

The U.S. Department of the Treasury finalized an interim rule on Tues= day aimed at setting up policies and procedures to help assist in the timel= y, successful and economical execution of the IRS’ contract actions. Read more »

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

Trump Nominates Judges For 3rd= , 11th Circuits

President Donald Trump announced his latest wave of judicial nominees= Tuesday, choosing a lawyer with Buchanan Ingersoll & Rooney PC for the Thi= rd Circuit, a Georgia Supreme Court judge for the 11th Circuit and a partne= r at Covington & Burling LLP to the U.S. Tax Court. Read more »

FEDERAL

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=09=09=09=09

Analysis

IRS Could Replace O= ffshore Voluntary Disclosure Program

With the IRS Offshore Voluntary Disclosure Program coming to a close = in September, willful violators who do not use the program could face penal= ties of at least $100,000 or up to half of their foreign accounts for certa= in misconduct, but it is possible the agency may create a replacement progr= am in the future. Read more »

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

UK Lawyer Convicted= For Helping Heirs In $14M Tax Dodge

A Manhattan jury on Tuesday convicted English lawyer Michael Little o= f 19 criminal counts, finding him guilty of helping the children of decease= d investor Harry Seggerman avoid paying tax on $14 million of inheritance m= oney and of dodging his own taxes. Read more »

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

Bondholders Ratch= et Up Puerto Rico Sales Tax Revenues Spat

Holders of Puerto Rico’s general obligation bond debt waged a c= ourt fight Tuesday over the territory’s sales tax revenues, telling a= New York federal judge that the island’s constitution overrides comp= eting bondholder claims to more than $17 billion in pledged sales tax colle= ctions. Read more »

STATE & LOCAL

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

=09=09=09=09

Analysis

Int'l Tariffs Pose = Threat To Local Economies, Jobs, Taxes

A growing trade dispute between the U.S. and China that has seen an e= scalation in tariffs being levied by both countries will have a major impac= t on state and local economies, jobs and taxes, experts say, particularly o= n places that rely heavily on international trade. Read more »

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

Ill. Gov. Calls For Bala= nced Budget Without New Taxes

Illinois Republican Gov. Bruce Rauner on Monday called for a meeting = this week with state House and Senate leaders to outline his proposal for a= balanced, full-year budget for 2019 that would not add any new taxes. Read more »

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

Average Deductions = Exceed SALT Limit In 19 States: Report

Taxpayers’ state and local tax deductions in 19 states and the = District of Columbia on average exceeded the $10,000 limit included in the = recent tax legislation, a study from the Pew Charitable Trust released Mond= ay found. Read more »

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

IRA Exempt From Deb= t Collection, Ill. Appeals Court Rules

An Illinois appellate court on Monday reversed a trial court’s = finding that a man’s IRA was not exempt from being included in a debt= collection, writing in its opinion that the collecting bank’s brief = was written so carelessly that the appellate panel had no choice but to str= ike it. Read more »

INTERNATIONAL

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

Australian Tax= Office Faces Inquiry Over Collection Practices

Australia’s tax collector is facing a government investigation = following whistleblower allegations accusing the office of encouraging its = staff to target vulnerable taxpayers in revenue grabs, the Australian Broad= casting Corp. reported Tuesday. Read more »

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

Apple Stores In France= Face Protests After Court Loss

Activists who claim Apple Inc. and other major multinational corporat= ions are dodging taxes have organized protests outside two of the tech gian= t’s stores in France, a move that follows a High Court of Paris decis= ion that rejected the company’s efforts to ban the group from its ret= ail outlets across the country. Read more »

EXPERT ANALYSIS

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

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

Your Guide To Wayfair: The Brief= s In Support

In this four-part article series covering South Dakota v. Wayfair, Da= vid Fruchtman of Rimon PC, analyzes all of the briefs submitted in this lan= dmark Supreme Court case as well as the oral argument and the decision in t= he matter.=20 Read more »

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

Chicago Tax Revenue= Scheme May Not Be Bankruptcy-Proof

Chicago has securitized its sales tax revenue to take advantage of th= e bankruptcy-remote mechanism and lower interest rates. However, an analysi= s of the transfer shows it may be classified as a financing, not a true sal= e, and may not be as bankruptcy-proof as hoped, says Raphael Janove of Eime= r Stahl LLP. Read more »

=09=09=09=09

Series

Dissolving Practice= : How To Fix A Dysfunctional Law Firm

I am often asked, “When there are one or more partner departure= s, what can a firm do to prevent this from escalating to a catastrophic lev= el?” The short answer is “nothing.” Law firms need to ado= pt culture-strengthening lifestyles to prevent defections from occurring in= the first place, says Larry Richard of LawyerBrain LLC. Read more »

LEGAL INDUSTRY

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

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

Firms Must Brace Fo= r AI Revolution, Legal Marketers Told

While the legal profession has trailed other fields in its adoption = of artificial intelligence tools, that is certain to change within the next= few years and the implications for both legal departments and law firms wi= ll be profound, a panel of experts told legal marketers at a conference in = New Orleans on Tuesday. Read more »

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

Ex-Christie Atty Called Back= To 3rd Circ. Roots

The career of onetime Third Circuit judicial clerk Paul B. Matey, wh= o has since made his mark on New Jersey’s legal scene as former Gov. = Chris Christie's counsel and a hospital executive, is coming full circle wi= th his nomination to the federal appellate bench Tuesday. Read more &= raquo;

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

Clark Hill, Strasburger & Pric= e Announce Merger

Detroit's Clark Hill, with its more than 450 attorneys and 17 office= s, and Texas-based Strasburger & Price, which has nearly 200 attorneys = across nine offices, will officially merge on Wednesday, the firms announce= d Tuesday. Read more »

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

Senate Confirms Frost = Brown Partner For Ky. Judgeship

The Senate confirmed President Donald Trump's nominee for a dual pos= t to two Kentucky judicial districts on Tuesday, marking the 29th judge to = be confirmed since the start of his presidency. Read more = »

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

Legal Tech Download: Walmart, = O'Melveny And GE

The world of legal technology is quickly evolving, with new products= coming to market in rapid succession. Here, Law360 takes a look at eight r= ecent developments. Read more »

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

Calif. Justice Wan= ts Court Sex Harass Deals To Name Names

California Chief Justice Tani Cantil-Sakauye said Tuesday she wants = state courts to disclose the names of all judicial officers who enter settl= ements to resolve sexual harassment or sexual discrimination complaints, ca= lling for an expedited change to court rules on public records. Read more »

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

Fed. Committee Back= s Tougher Corporate Deposition Rule

The federal judiciary's Advisory Committee on Civil Rules on Tuesday= approved rule changes designed to quell discovery disputes and time-wastin= g over depositions of corporate representatives. Read more &r= aquo;

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