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Results: 1-10 of 34

California court finds securitization entities subject to California income tax

  • Reed Smith LLP
  • -
  • USA
  • -
  • May 13 2013

A California Superior Court has issued a decision with significant impact on financial services. In the case, Harley-Davidson, Inc. v. Franchise Tax

What matters: A review of 2011 and 2012

  • Kramer Levin Naftalis & Frankel LLP
  • -
  • USA
  • -
  • April 1 2013

As you know, the last two years have seen a somewhat improved, but by no means robust, business climate. At the same time, structural shifts in the

If you thought the IRS would not punish 409A foot faults, think again

  • Winston & Strawn LLP
  • -
  • USA
  • -
  • March 26 2013

The result in the case Sutardja v. U.S., decided by the United States Court of Federal Claims last month is not surprising. We all understood the

BLG Monthly Update

  • Borden Ladner Gervais LLP
  • -
  • Argentina, Australia, Canada, United Kingdom, USA
  • -
  • December 19 2012

The BLG Monthly Update is a digest of recent developments in the law which Neil Guthrie, our National Director of Research, thinks you will find

The Southern District of New York finds alleged misrepresentations about internal controls sufficient on a stand-alone basis to state a securities fraud claim

  • Simpson Thacher & Bartlett LLP
  • -
  • USA
  • -
  • November 30 2012

On November 7, 2012, the Southern District of New York declined to dismiss securities fraud claims concerning alleged misrepresentations regarding Weatherford International Ltd.’s internal controls, even though the court found that the plaintiffs had failed to state a claim as to the tax understatement that resulted from Weatherford’s internal control failures

Rare taxpayer debt-equity win

  • Alston & Bird LLP
  • -
  • Netherlands, USA
  • -
  • November 28 2012

Pepsico, Inc., and Pepsico Puerto Rico, Inc. v. Commissioner, T.C. Memo 2012-269, ruled that the U.S. holder of an ambiguous security issued by its foreign affiliate did not have to treat the periodic payments received as interest, even though the affiliate was deducting interest paid under Dutch tax law

The “fiscal cliff”: look before you leap into a securities litigation trap

  • Choate Hall & Stewart LLP
  • -
  • USA
  • -
  • October 23 2012

The possibility of expiring tax cuts combined with mandatory reductions in federal spending at year end have prompted observers to warn that the US faces a “fiscal cliff” over which the economy might well plunge into another recession

What is a trade or business and why does it matter?

  • Leonard, Street and Deinard
  • -
  • USA
  • -
  • May 16 2012

If an employer withdraws from a multiemployer plan and is assessed withdrawal liability, all members of the employer’s controlled group are liable for that assessment

CFTC sues Royal Bank of Canada for years long wash sale scheme

  • Dorsey & Whitney LLP
  • -
  • Canada, USA
  • -
  • April 4 2012

The Commodity Futures Trading Commission filed an enforcement action against the Royal Bank of Canada alleging a years long, riskless wash sale scheme conducted by a small group of RBC personnel to generate certain lucrative Canadian tax benefits

US political law compliance and risk management

  • Dentons
  • -
  • USA
  • -
  • April 3 2012

The influence of Super PACs on the Republican presidential primary has been well-documented

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