Virginia

Narrower Harbors: Supreme Court Holds that ยง 546(e) Securities Safe Harbor Does Not Protect Transfers in Which Financial Institution Is Only a Conduit By Kevin C. Maclay, Todd E. Phillips, and 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.[1]  These avoidance powers are, however, limited by a number of exceptions enumerated in the Bankruptcy Code, including the securities safe harbor at § 546(e). […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

IRS Guidance Removes Obstacle to Restructuring Tax-Exempt Organizations

Under newly issued guidance, the IRS has made it easier for many tax-exempt organizations to restructure. The IRS will now continue to recognize as exempt, those organizations that: change their structure from an unincorporated association to a corporation; reincorporate from one state to another; domesticate in a new state; or merge one corporation with or […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

World Bank Survey – Overview 434.00

I have attached, in Adobe Acrobat .pdf format (see link HERE,) the Overview from the World Bank Group’s Flagship Report-Doing Business, plus the United States reference page that ShawnCoulson, LLP worked on. Taken from: World Bank. 2018. Doing Business 2018: Reforming to Create Jobs. Washington, DC: World Bank. DOI: 10.1596/978-1-4648-1146-3. License: Creative Commons Attribution CC BY 3.0 […]

William H. ShawnCo-Managing Partner, ShawnCoulson

INSIGHT: First Class, Global Entry, and Now Tax Compliance: the New Must-Have for Today’s International Traveler

Join Our Email Distribution List   INSIGHT: First Class, Global Entry, and Now Tax Compliance: the New Must-Have for Today’s International Traveler  Bloomberg Tax: Daily Tax Report March 6, 2018   Dianne Mehany and Arielle Borsos of Caplin & Drysdale discuss the IRS’s plans to implement the 2015 passport revocation statute, which authorizes the IRS to […]

James P. (Jim) WehnerMember, Caplin & Drysdale, Chartered

IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018

As detailed in our prior alert (here), Congress enacted Fixing America’s Surface Transportation Act (the “FAST Act”) in December 2015 and authorized the Internal Revenue Service (“IRS”) to notify the Department of State (“State Department”) when any individual has a “seriously delinquent tax debt.”  After receiving notice, the Secretary of State may deny that person […]

James P. (Jim) WehnerMember, Caplin & Drysdale, Chartered

New IRS Procedures Will Impact Nonprofits

The IRS has announced procedural changes that will impact exempt organizations in 2018.  These changes concern new organizations and organizations that have lost exemption due to automatic revocation.  They also affect any organization where the IRS is proposing to retroactively revoke its exemption as a result of an IRS examination.   The most significant changes […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

New Partnership Audit Rules Go Live

The Bipartisan Budget Act of 2015 (“BBA”) fundamentally changed the rules by which partnerships, and entities taxed as partnerships (such as limited liability companies), interact with the Internal Revenue Service (“IRS”) in an audit or litigation.  The new rules apply to partnership tax years beginning on or after January 1, 2018.  We outlined these significant […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

Crenshaw, Ware & Martin, P.L.C. Newsletter

Dan Bever Joins the Firm We are pleased to announce that Daniel A. Bever has joined CWM as an associate attorney. His practice will focus on Commercial Real Estate, Project Finance, and Public Sector law.  Dan previously served as a law clerk for the Tax Division of the United States Department of Justice, as a law […]

James L. Chapman, IVIR Global Engagement Partner, Crenshaw, Ware & Martin, P.L.C.

Will the IRS Know What Gifts Prince Harry Gives Meghan Markle for Christmas?

The recent engagement of Prince Harry and Meghan Markle raises an intriguing question regarding the distinction between marital support and gifts. One may initially find this a pedantic inquiry, but it is a question that frustrates planning for many international tax practitioners advising couples with one U.S. spouse and one non-U.S. spouse.   A U.S. […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations

The recent FBI probe into fraud and bribery in NCAA men’s basketball has produced articles and commentary on the reality of student athlete recruiting and the potential impact on powerhouse programs.  What has been ignored is the tax impact and consequences on the players and their families. The possible exposure for any player and/or family […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered

Supreme Court to consider statutory safe harbour for debtors’ pre-petition securities transactions

Introduction Does the Bankruptcy Code bar a bankruptcy trustee from avoiding a debtor’s constructivel fraudulent pre-petition securities transactions merely because the deal was executed through a financial intermediary with no stake of its own in the transaction? The Supreme Court will address this question in Merit Management Group, LP v FTI Consulting, Inc.(1) The issue […]

Jeffrey A. LiesemerMember, Caplin & Drysdale, Chartered