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  • Article

    A Divided Court Holds That Under The Federal Arbitration Act An Ambiguous Agreement Cannot Provide A Basis For Compelling Class Arbitration

    In 2016, Lamps Plus was the victim of a phishing attack, which resulted in the improper dissemination of employee data.
    United StatesLitigation, Mediation & Arbitration
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Biden's Proposed Tax Increases – How Do They Affect Bona Fide Residents Of Puerto Rico?

    The Biden Administration published its Green Book of tax proposals on May 28, 2021.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Global Netting: Potential Opportunities For Corporate Taxpayers

    Two recent judicial decisions addressing the so-called "global netting" of interest in tax cases potentially offer corporate taxpayers new opportunities.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    CARES Act Assistance For Nonprofit Employers: Loans, Emergency Grants And Other Assistance

    On March 27, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act was signed into law.
    United StatesCoronavirus (COVID-19)
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Treasury Proposes Significant Changes To U.S. Model Tax Treaty

    On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model).
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Campaign Finance: Remedies Beyond The Court

    It is difficult to overstate the impact of the Supreme Court’s Citizens United decision.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Strategic Resets Under The New MAP And APA Revenue Procedures

    The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    CARES Act Offers Income Tax Relief For Business

    On March 27, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act was passed to stabilize the flagging U.S. economy.
    United StatesCoronavirus (COVID-19)
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Wins Big In The Coca-Cola Company & Subs. v. Commissioner

    On November 18, 2020, the Tax Court ruled that respondent IRS had not abused its discretion under § 482 when it reallocated more than $9 billion in income for 2007-2009 to petitioner Coca-Cola from its foreign manufacturing affiliates.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    OECD Announces A Public Consultation For Global Minimum Tax Rules

    On November 8, the OECD announced a request for comments and a December 9 public consultation on its Global Anti-Base Erosion proposal, which would further the work of the BEPS Project by ...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Pillar One And Pillar Two: The Well-Intentioned (But Unfortunate) Pursuit Of Perfection

    For 300 years, the principle known as "the revenue rule" sharply limited collaboration among nations with respect to tax. In the seminal 1729 court decision of Attorney General v. Lutwydge...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The State Of Expatriation 2011 - Part 2

    Under broad regulatory authority contained in section 6039G, the 2009 Notice expands the reporting that is due from covered expatriates in years following the year of expatriation.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    There's No Elephant In This Mousehole: The Supreme Court Upholds State Court Jurisdiction Over Class Actions Brought Under The Securities Act Of 1933

    Justice Kagan, writing for the court, first examined the interrelationship between the three relevant acts.
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Second Circuit Holds Arbitration Of Alleged Violation Of Discharge Injunction Conflicts With Purposes Of Bankruptcy Code

    Recently, in Anderson v. Credit One Bank, N.A., the Second Circuit affirmed the denial of a credit card issuer's attempt to compel arbitration of a discharged Chapter 7 debtor's putative class action...
    United StatesLitigation, Mediation & Arbitration
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    In The Room Where It Happens, It Doesn't Always Happen Exactly Right

    Today we continue our series highlighting the recent publication of the Pittsburgh Tax Review edition focusing on the Restructuring & Reform Act of 1998 a quarter century after enactment.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Possible Repeal Of The Estate Tax In 2017

    The election of Donald Trump as the next President, along with continued Republican party control of both the House and the Senate, could signal that 2017 will be the year that the estate tax is repealed.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The Gift Tax And Contributions To Section 501(c)(4) Organizations: Less Than Meets The Eye?

    News reports suggesting that the IRS has opened federal gift tax examinations of five donors to section 501(c)(4) nonprofit organizations have generated considerable concern over the past few weeks.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    FATCA: A New Era Of Financial Transparency

    The IRS's powerful new tool chips away at bank secrecy.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Remain Vigilant On Indian Permanent Establishments, Even After The Favorable e-Funds Decision

    The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    What You Really Need To Know About Transfer Pricing

    The Editor interviews Patricia Gimbel Lewis, Member of Caplin & Drysdale, Chartered’s Washington, DC office.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered

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