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Caplin & Drysdale, Chartered

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Article
Making Their Mark: The Supreme Court Clarified And Reshaped Class Action Law In The October 2010 Term
The recent Supreme Court term has produced several decisions that will have a far-reaching impact on future class action litigation.
United StatesLitigation, Mediation & Arbitration
Caplin & Drysdale, Chartered
Article
Deferred Prosecution Agreements: Implications for Corporate Tax Departments
Tax enforcement is back in vogue. In the past few years, the Internal Revenue Service has dramatically ramped up its compliance functions. The budget for tax enforcement has increased, additional agents are on board, and the tax community is witnessing an increase in examination, tax litigation, and criminal investigation activity. The IRS has become more aggressive in pursuing companies, law firms, and accounting firms through the examination and summons processes.
United StatesTax

Caplin & Drysdale, Chartered

The Final State Of Expatriation? - Part 1

Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART” or the “Act”) dramatically alters the playing field for individuals who relinquish their U.S. citizenship or terminate their long-term U.S. residence (i.e., U.S. persons who “expatriate”).

United StatesTax

Caplin & Drysdale, Chartered

Tsunami: NGO Response: Now and the Future

The tsunami disaster sounds a clarion call not only to governments to reexamine their international responsibilities, but also to the international NGO community to review its coordination policies and delivery of services to the most needy throughout the world through indigenous NGOs of the countries affected.

United StatesTax

Caplin & Drysdale, Chartered

Curing Non-Compliance: Practical Factors to Consider in the United States - Part 1

The rules that govern a taxpayer's obligation to file a tax return and pay taxes in the United States - principally the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and the Treasury regulations and administrative practices and procedures thereunder – are exceedingly complex.

United StatesTax

Caplin & Drysdale, Chartered

Foreign Trust Reporting And Compliance - Part 2

Form 3520 has several uses, which may cause confusion. Generally, Part 1 covers transfers to a foreign trust by a U.S. person, including a U.S. citizen or resident alien, a U.S. domestic partnership, corporation, trust or estate.

United StatesTax

Caplin & Drysdale, Chartered

Developments in Offshore Tax Compliance

Who Has Foreign Accounts and Assets?

United StatesTax

Caplin & Drysdale, Chartered

Survival Techniques: Transfer Pricing In A Sick Economy

Times are tough. But as multinational businesses wrestle with serious economic pressures, transfer pricing remains central to ultimately balancing their global tax burdens and minimizing tax controversies.

United StatesTax

Caplin & Drysdale, Chartered

Foreign Trust Reporting And Compliance, Part One

The United States generally imposes an income tax filing requirement on all U.S. persons and certain foreign persons, including certain foreign trusts with U.S. owners or other U.S. nexus.

United StatesTax

Caplin & Drysdale, Chartered

The Final State Of Expatriation?

Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART” or the “Act”)1 dramatically alters the playing field for individuals who relinquish their U.S. citizenship or terminate their long-term U.S. residence (i.e., U.S. persons who “expatriate”).

United StatesTax

Caplin & Drysdale, Chartered

Three Can Keep A Secret, If Two Of Them Are Dead: A Thought Experiment Around Compelled Public Disclosure Of "Anonymous" Political Expenditures

"Three can keep a secret, if two of them are dead." Variously attributed to Benjamin Franklin and the Hell’s Angels.

United StatesCorporate/Commercial Law

Caplin & Drysdale, Chartered

Safe at Last? Transfer Pricing Safe Harbors On The Horizon

With the release last month of a discussion draft on proposed revisions to Chapter IV of its transfer pricing guidelines.

United StatesTax

Caplin & Drysdale, Chartered

The State Of Expatriation 2011 - Part 1

Section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008 ("HEART" or the "Act") dramatically alters the playing field for individuals who relinquish their U.S. citizenship or terminate their long-term U.S. residence (i.e., U.S. persons who "expatriate").

United StatesTax

Caplin & Drysdale, Chartered

The New U.S.-Italy Treaty: A U.S. Perspective

On March 3, 2009, the Italian Parliament approved a new U.S.-Italy income tax treaty, which had been signed on August 25, 1999.

United StatesTax

Caplin & Drysdale, Chartered

Foreign Trusts: Everything You Wanted To Know About The Taxation Of Foreign Trusts But Were Afraid to Ask

The U.S. taxation of foreign trusts and trusts with foreign grantors was altered substantially by the Small Business Job Protection Act of 1996 ("1996 Small Business Act") and the Taxpayer Relief Act of 1997 ("1997 TRA")

United StatesTax

Caplin & Drysdale, Chartered

Corporate Tax Departments and the New Focus on Corporate Criminality

In little more than a year a combination of events have reshaped the relationship between corporations, corporate management, and the criminal law.

United StatesGovernment, Public Sector

Caplin & Drysdale, Chartered

Undeclared Foreign Accounts— Voluntary Disclosures And FBARs After The IRS Settlement Initiative

For the past two years, the worldwide business press has been full of stories about potentially thousands of U.S. taxpayers who may have undeclared accounts in Switzerland, Liechtenstein and other foreign countries.

United StatesTax

Caplin & Drysdale, Chartered

Markers and Musings:The Proposed Section 482 Services Regulations

In September, the Internal Revenue Service promulgated comprehensive and important revisions to the regulations regarding the treatment of intercompany services under section 482 of the Internal Revenue Code, along with several key changes to the transfer pricing characterization of intangibles

United StatesEmployment and HR

Caplin & Drysdale, Chartered

The Nuts And Bolts Of Deficiency Cases: From Examination To The Tax Court

You can avoid surprises when you know the process.

United StatesTax

Caplin & Drysdale, Chartered

IRS’s Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year - Part 1

Exactly one year ago, the tax world watched as the Internal Revenue Service conducted what may have been the most extraordinarily successful tax compliance feat in American history.

United StatesTax

Caplin & Drysdale, Chartered

Showing 401–420 of 426 results

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