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Federal Tax Reform Includes Traps For Deferred Compensation Deals
Last October, President Bush signed into law the American Jobs Creation Act of 2004. This 2004 Tax Act amended nearly 600 sections of the Internal Revenue Code (IRC), thereby making far-reaching changes to many areas of tax law. While the major focus of the 2004 Act was to provide tax relief for U.S. corporations repatriating earnings back to the United States, this new legislation also provided numerous revenue-raising provisions and tax cuts that affected corporate and individual taxpayers and special interest groups, from film producers to owners of sports teams.
In fact, the 2004 Act affects the entertainment industry in numerous ways. The Act contains a variety of provisions that are specifically targeted at the entertainment industry, including new rules creating current deductions for small films made predominantly in the United States, and an amendment to the income-forecast method of depreciation. The Act also includes provisions that, though not targeted exclusively at the entertainment industry, have an intended and foreseeable impact on the industry, such as the new deduction for domestic production activities.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The DOJ's New Parameters for Evaluating Corporate Compliance Programs
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
Use of Deferred Prosecution Agreements In White Collar Investigations
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
A Lawyer's System for Active Reading
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.