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Caplin & Drysdale
 
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By Zhanna Ziering, Dianne Mehany, Arielle Borsos, Scott D. Michel, Mark E. Matthews
On November 29, 2018, the IRS released updated Voluntary Disclosure Practice (VCP) procedures applicable to both offshore and domestic voluntary disclosures
By H. David Rosenbloom, Jonathan Brenner, Josiah Child
The change would alter current practice in the commercial loan market in the case of a U.S. issuer borrowing with credit support from its CFCs.
By Charles Ruchelman, Rachel Partain, Aaron M. Esman
Summer 2018 proved to be an active time in the implementation cycle of the new partnership audit regime, created under the Bipartisan Budget Act of 2015 ("BBA").
By Jonathan Brenner, Victor Jaramillo, Arielle Borsos
Although the guidance clarifies many areas of ambiguity, it leaves many important questions unanswered.
By Caplin & Drysdale
The Tax Cuts and Jobs Act changed the way tax-exempt organizations calculate their unrelated business taxable income.
By Kevin Maclay, Todd Phillips, Sally J. Sullivan
The court then found that failing to respond to a served summons and complaint constituted such a waiver.
By Todd Phillips, Kevin M. Davis, Kevin Maclay
Recently, in Anderson v. Credit One Bank, N.A., the Second Circuit affirmed the denial of a credit card issuer's attempt to compel arbitration of a discharged Chapter 7 debtor's putative class action...
By Arielle Borsos, Victor Jaramillo, Kirsten Burmester, Dianne Mehany, Anne O’Brien, Michael Pfeifer
On May 21, 2018, the IRS Large Business and International division added foreign trust information reporting to its "compliance campaigns," signaling that the IRS sees a "compliance risk" in this area ...
By Trevor Potter, Matthew Sanderson, Bryson Morgan, Emma K. Lewis
Late last year, many social media and internet giants announced plans to overhaul their advertising policies for political content.
By Todd Phillips, Kevin Maclay, Caroline E. Parke
Justice Kagan, writing for the court, first examined the interrelationship between the three relevant acts.
By Trevor Potter, Matthew Sanderson, Bryson Morgan, Emma K. Lewis
Last fall, Facebook announced a disclosure program for users of its platform specifically aimed at requiring disclosures for election-related advertising.
By Trevor Potter, Matthew Sanderson, Bryson Morgan, Emma K. Lewis
Failure to comply with these requirements could result in a civil penalty of up to $1,000 per violation.
By Kevin Maclay, Todd Phillips, Caroline E. Parke
Recent caselaw demonstrates that there is a current judicial disagreement over whether the Bankruptcy Code will permit a cramdown in a jointly-administered bankruptcy case...
By Todd Phillips, Kevin Maclay, Jeanna Koski
On March 5, 2018, the Supreme Court issued a unanimous decision in U.S. Bank National Ass'n ex rel. CWCapital Asset Management LLC v. Village at Lakeridge, LLC, holding that bankruptcy court determinations ...
By Kevin Maclay, Todd Phillips, Kevin M. Davis
The Bankruptcy Code provides bankruptcy trustees, debtors, and creditor committees with "avoidance powers" that allow them to set aside and recover certain transfers that a debtor made before filing for bankruptcy.
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