Substantive non-consolidation opinion letters have long been a regular "check-the-box" item in large commercial real estate transactions. While substantive consolidation jurisprudence has not changed materially over the past decade, these opinion letters should not be treated lightly by borrowers or their counsel.
A Business Expense?
In negotiating FCA or similar settlements with the government, one key consideration is the tax treatment of any payment. While not in the context of deductibility, the Supreme Court this year, inKokesh v. SEC, analyzed whether disgorgement in an SEC enforcement action was punitive or compensatory.
Will big law firms and their partners benefit from the new Republican tax plan promoted by President Donald Trump? Not necessarily, according to tax experts who say some gains may be eroded by loss of crucial deductions.
For tax professionals, particularly those who specialize in the area of state and local taxes, nexus is a topic that is discussed all too often. Nexus rules have lagged behind the ever-changing economic landscape, but states are beginning to catch up. Nonetheless, the nexus rules are very important for professional services firms such as law firms.
A Southern California assemblyman on Monday shelved legislation that would have blocked cities from taxing streaming video services such as Netflix and Hulu.
How to Avoid the Tax Pitfalls of 26 U.S.C. §956 when Negotiating Lending Transactions for Clients with Foreign Country Operations
A popular conduit for operating in a foreign country is a controlled foreign corporation (CFC). In 2012, U.S.-controlled foreign corporation earnings topped $793 billion as the world economy became increasingly interconnected. See, IRS, Statistics of Income. How does the aforementioned trend impact the legal profession?
Part Two of a Two-Part Article
A discussion of the trust issues that can arise in the context of matrimonial practice.
Compensation provisions in entertainment contracts are in one or two subparagraphs. To simplify drafting and to use “plain English,” the compensation provisions often contain introductory, governing language along the lines of: “In full and complete consideration for entering into and performing all of the terms hereof.” However, is such a “plain English” approach always a “best practice”?
One of the rare legal issues in which bankruptcy practitioners usually are able to speak to clients in absolute terms to provide clear legal advice is the limitations period concerning the pursuit of avoidable transfers in bankruptcy proceedings.
