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New York Court Rules on Premium Deduction  (June 2016)
Captive Insurance Company Reports
The New York State Division of Tax Appeals was recently faced with the issue of whether a premium paid to a captive was a valid deduction for the purposes of determining the corporate franchise tax ...
Harry Potter and the Compliance Stone: SEC and FINRA Enforcement Actions Against Compliance Officers (May-June 2016)
Practical Compliance and Risk Management for the Securities Industry
While Harry Potter has spells, potions, wands, invisibility cloaks and a team of friends to assist him, chief compliance officers (CCOs) must help ensure that their firms comply with securities rules ...
Unclaimed Property Auditors Move Beyond Life Insurers (May 24, 2016)
The same contingency-fee unclaimed property auditors that targeted life insurance companies are now turning their focus to other types of insurance, including health insurance and property and ...
Strategic Actions to Keep the Asian Rebalance and U.S.-Japan Security Cooperation on Track (May 24, 2016)
Defense News
Beyond the deep symbolism of President Barack Obama’s visit to Hiroshima later this week, his trip to Vietnam and Japan reflects the sustained U.S. commitment to the rebalance toward the Asia — in ...
A Pinch of SALT: Funky Federal Doctrines Flourish in the SALT World (May 23, 2016)
State Tax Today
Even those of us who practice in the state and local tax field have been exposed to federal judicial tax doctrines. The business purpose, substance-over-form, sham transaction and step transaction ...
Protecting Against Financially Distressed Counterparties (May 13, 2016)
Dealing with distressed counterparties presents multiple challenges to any lawyer and any organization. In their article for Law360, Sutherland attorneys David Baay, Mark Sherrill and Travis ...
IRS: Status of Coverages (May 2016)
Captive Insurance Company Reports
In early March 2016, the Internal Revenue Service published LTR 201609008 which, on its face, seems to characterize a number of coverages as lacking insurance risk and not constituting insurance in ...
Ohio Tax Litigation Reflects Evolving Nexus Landscape  (May 6, 2016)
The Ohio Supreme Court recently heard oral arguments in three cases that could test the constitutionality of the Ohio commercial activity tax (CAT). These cases turn on whether the CAT’s ...
Issues For ‘Lonely’ Life Companies Under New Debt-Equity Regulations (May 4, 2016)
Recently proposed Treasury regulations under IRC §385 would, in certain instances, treat related party debt instruments as stock for U.S. federal tax purposes. Although the proposed regulations ...
Planning Defense M&A After Recent Government Guidance: Part 2 (May 3, 2016)
A series of unusual statements issued by the U.S. government in recent months has provided guidance on, and raised questions about, consolidation in the defense industry. In light of a statement by ...
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