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New York State Department of Labor Issues Model Sexual Harassment Policy and Interactive Training Documents: Employers Must Adopt New Policy by October 9, 2018 and Provide Training by January 1, 2019
  • Sullivan & Cromwell LLP
  • USA
  • September 19 2018

New York's 2018-2019 State Budget contained several significant pieces of legislation addressing workplace sexual harassment, which we reviewed in our


IRS Releases Initial Guidance on the Internal Revenue Code’s “UBTI Silo” Rule
  • Sullivan & Cromwell LLP
  • USA
  • September 19 2018

The Internal Revenue Service (the "IRS") recently released Notice 2018-67 (the "Notice"), providing initial guidance for tax-exempt organizations


SEC Staff Withdraws Proxy Advisory Guidance Ahead of Fall Roundtable on Proxy Process
  • Sullivan & Cromwell LLP
  • USA
  • September 14 2018

Yesterday, the SEC's Division of Investment Management withdrew two interpretive letters issued in 2004 to Egan-Jones Proxy Services and Institutional


CFTC Chairman Previews New Approach to Cross-Border Application of Dodd-Frank Swaps Provisions, Exemptions
  • Sullivan & Cromwell LLP
  • USA
  • September 7 2018

On September 4, 2018 at a City of London event, the Chairman of the U.S. Commodity Futures Trading Commission (the "CFTC"), Christopher Giancarlo


UpdateImportant Amendments to the California Consumer Privacy Act of 2018: California State Legislature Amends Recently Enacted California Privacy Statute to Include Key Clarifications and Additional Exemptions for Businesses
  • Sullivan & Cromwell LLP
  • USA
  • September 6 2018

On August 31, 2018, the California State Legislature passed a bill, SB-1121 (the "Amendments"), amending the recently enacted California Consumer


Community Reinvestment Act: OCC Issues Advance Notice of Proposed Rulemaking to Improve the Regulatory Framework Implementing the Community Reinvestment Act
  • Sullivan & Cromwell LLP
  • USA
  • September 4 2018

On August 28, the Office of the Comptroller of the Currency published an advance notice of proposed rulemaking (the "ANPR") soliciting "ideas for


Proposed Section 965 Regulations: Proposed Regulations Follow Earlier Guidance With Modifications and Additions
  • Sullivan & Cromwell LLP
  • USA
  • August 31 2018

Section 965 of the Internal Revenue Code, enacted as part of the comprehensive tax reform bill commonly known as the Tax Cuts and Jobs Act of 2017


United States v. HoskinsSecond Circuit Rejects DOJ’s Attempt to Expand the Extraterritorial Reach of the FCPA Through Conspiracy and Complicity Doctrines:
  • Sullivan & Cromwell LLP
  • USA
  • August 27 2018

On August 24, 2018, in United States v. Hoskins, the United States Court of Appeals for the Second Circuit affirmed in part and reversed in part a


Tax Reform and State and Local Taxation: IRS Issues Proposed Regulations on Charitable Contributions and State and Local Tax Credits and Deductions
  • Sullivan & Cromwell LLP
  • USA
  • August 24 2018

On August 23, 2018, the Department of the Treasury (the "Treasury Department") and the Internal Revenue Service (the "IRS") issued proposed


IRS Releases Initial Guidance on the 2017 Amendments to the Internal Revenue Code’s Limitation on Deduction for Certain Executive Compensation
  • Sullivan & Cromwell LLP
  • USA
  • August 23 2018

The IRS released Notice 2018-68 (the “Notice”) on August 21, 2018, which provides initial guidance on changes made to the Internal Revenue Code (the