The Internal Revenue Service has recently ramped up compliance and enforcement efforts with budget increases and enhanced resources. A lesser-known component of this revitalized enforcement is the IRS Office of Professional Responsibility (OPR), which is charged with regulating professionals ' mostly lawyers and accountants ' who practice before the IRS. OPR enforces ethical rules that govern practice before the Service, commonly known as "Circular 230," and may sanction practitioners who violate those rules. Because OPR matters can interact with the criminal process in many respects, conscientious white- collar practitioners and corporate tax counsel should familiarize themselves with OPR and its power over tax professionals.

The work letter that is attached to a lease, particularly an office lease, is a very important part of the lease document. Because it is an exhibit, and because many leasing professionals are not especially well versed in construction issues, the work letter is frequently given little attention during a lease negotiation.

Highlights of the latest commercial leasing cases from around the country.

Features

When considering a new lease for a single use property, generally the tenant of the property will want to consider its "exit" strategies at the time of the initial negotiation of the lease. Potential "exit" strategies may include: assignment of the lease, early termination rights and options to purchase the property. The last on the list of these "exit" strategies, options to purchase the property, often creates substantial business issues for the landlord and tenant, as well as drafting issues for their legal representatives. As a result, certain conceptual issues, set forth and discussed below, should be addressed when drafting an option to purchase the property.

The United Air Lines bankruptcy case has spawned several reported decisions, at the bankruptcy court level, the district court level and the circuit court level.

Is the landlord's right to cure a defect in the premises a perpetual one? The answer depends on where you are, what your lease says, and whether you have documented complaints and repairs adequately.

…

Features

Parties to all international contracts face different issues depending on whether the other contracting party is a privately owned enterprise or a State-owned entity. In both circumstances, the foreign investor may have legitimate concerns about the partiality the local judiciary may have towards parties from its own State if a contractual dispute arises and about the enforceability of any judgment against the local party. When the other contracting party is itself a Sovereign State, the foreign investor confronts the universal perception ' if not actual reality ' that a judiciary as a government entity may be controlled by the State and biased against the investor. <br>For international transactions, arbitration in a neutral forum offers the hope of reducing bias and avoiding parallel lawsuits in different countries.