Noncompensatory Options Regulations May Adversely Affect Holders, Buyers, and Historic Partners
February 14, 2013
On February 4, 2013, the Treasury Department promulgated final regulations concerning the treatment of "noncompensatory options," such as warrants and...
IRS Releases Proposed Regulations on Employer Shared Responsibility under the Affordable Care Act
January 28, 2013
On January 2, 2013, Treasury and the Internal Revenue Service ("IRS") published proposed regulations with respect to the employer "shared responsibility&quo...
The American Taxpayer Relief Act of 2012 Extends Tax Incentives for Renewable Energy Projects
January 23, 2013
President Obama signed the American Taxpayer Relief Act of 2012 on January 2, 2013 ("ATRA"). The ATRA is a component of the legislative response to the so-c...
Blowing the Whistle for Tax Dollars and Early Retirement: Views from the Perspectives of Both Whistleblowers and Taxpayers
December 06, 2012
While businesses have for some time been aware of the possibility of "tax whistleblowers" – employees or outside advisors who anonymously...
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Texas Power Plants Obtain TCEQ Ruling Supporting Pollution Control Property Tax Exemption for HRSGs
December 7, 2012
On December 5, 2012, the Texas Commission on Environmental Quality ("TECQ") explicitly affirmed that equipment that avoids polluting emissions solely by...
Fulbright Forum: Legal Ethics for In-House and Private Practice Lawyers When Dealing with Social Media
November 13, 2012
The internet is an integral part of virtually every lawyer's practice nowadays. Lawyers regularly use the internet to display their credentials, to post...
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Litigation of a Tax Exemption Dispute as to One Tax Year Does Not Apply to Subsequent Tax Years
November 6, 2012
A recent case from the Third Court of Appeals confirms that a property owner awaiting a decision on any type of application for exemption, or whose property has received...
Strategies for Defending 30(b)(6) Depositions
September 05, 2012
Under Federal Rule of Civil Procedure 30(b)(6), a corporation, partnership, association, or governmental agency is subject to the deposition process. If approached...
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New York Advisory Opinion Addresses Income Tax Treatment of Residence “Clubs”
September 13, 2012
In an Advisory Opinion released on September 11, 2012 (TSB-A-12(4)I), the New York State Department of Taxation & Finance concluded that a non-resident of New York...
Between Obamacare and the Bush Tax Cuts, Taxes Will Increase in 2013, But How Much? Can Planning Help?
August 27, 2012
Income and Employment Tax Changes
The Patient Protection and Affordable Care Act of 2010 ("Obamacare") will increase taxes for certain individual...
Company Beats IRS on Deductibility of Health Care Fraud Settlement
August 23, 2012
On August 15, 2012, Fresenius Medical Care Holdings, Inc., prevailed in a case involving the tax deductibility of a health care fraud settlement payments.
ISDA’s FATCA Protocol Published—Action Suggested
August 16, 2012
The International Swaps and Derivatives Association, Inc. (ISDA) announced via press release the launch of the ISDA 2012 FATCA Protocol. According to ISDA, the Protoc...
IRS Provides Updated Information For 2012 Offshore Voluntary Disclosure Program
August 1, 2012
The IRS recently released updated information regarding its 2012 Offshore Voluntary Disclosure Program (the "2012 OVDP") and modified the procedures for filing...
The Fast Track Appeals Process: Pointers & Pitfalls
July 19, 2012
Tax attorney Jasper "Jack" Taylor presented to the Houston chapter of the Tax Executives Institute, speaking on the tax appeals process...
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Tax Alert for Non-U.S. People Owning U.S. Property
June 26, 2012
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If you are a non-resident and non-citizen of the United States who owns U.S. assets (such as real estate or securities) or is considering acquiring a U.S. asset for your...