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In The Marketplace
IRS Provides Transition Relief for Tax-Exempt Leasing: The Internal Revenue Service and the Treasury Department have issued guidance providing limited transition relief for certain partnerships and other pass-through entities that are subject to Section 470 of the Internal Revenue Code, which was added by the American Jobs Creation Act of 2004.
This new provision addresses leases of property in sale-in, lease-out transactions involving tax-exempt entities by suspending the deduction for “tax-exempt use losses” on “tax-exempt use property.” This new provision also applies to certain partnerships. After receiving comments from taxpayers suggesting that certain partnerships may have difficulty applying this provision for 2004, the IRS and the Treasury Department determined that difficulties might exist for 2004 returns with respect to certain property owned by partnerships or other pass-through entities.
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.