Legal Alerts

Legal Alert: Supreme Court Unanimously Rules in Favor of Taxpayer, Holds U.K. Windfall Tax Creditable

May 22, 2013

Legal Alert: At Last: Final Regulations Issued Under Section 336(e)

May 13, 2013

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

May 3, 2013

Legal Alert: Proposed Legislation Would Sweep Certain Offshore Corporations into the U.S. Tax Net and Subject Their Worldwide Income to U.S. Tax

April 25, 2013

Legal Alert: New Budget Proposals Once Again Target Insurance Companies

April 15, 2013

Legal Alert: No Longer a Reserved Issue: IRS Concludes that the Statutory Reserve Cap Includes Deficiency Reserves

February 28, 2013

Legal Alert: One Shade of GRA: Proposed Regulations Foreshadow the End of the GRA Directive and Provide That "Available Upon Request" Is a "Willful Failure"

February 5, 2013

Legal Alert: Camping on "The Street": A First Step in the Reform of the Taxation of Financial Instruments and Products

January 29, 2013

Legal Alert: Many But Not All Retirement Savings Arrangements Unaffected by Proposed Net Investment Income Tax Regulations

December 4, 2012

Legal Alert: Much Ado About Nothing: The Tax Court Declines To Rule in Cigna Corp.

September 17, 2012

Legal Alert: A New FATCA Derivative: ISDA Publishes Protocol Designed To Address the Implications of FATCA on Derivatives Transactions

August 21, 2012

Legal Alert: Bringing Certainty to an Uncertain Tax Position: IRS LB&I Directive Addresses Partial Worthlessness Deductions Claimed by Insurance Companies

August 2, 2012

Legal Alert: FATCA G-5 Model Intergovernmental Information Sharing Agreements Released, with Substantial Benefits for Insurance Company FFIs (Including Reduced Due Diligence Burdens)

July 31, 2012

Legal Alert: The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshufflings

June 12, 2012

Legal Alert: A Secret No More: Final Treasury Regulations Amend the Controlled Group Deferred Loss “Supersecret Rule”

April 17, 2012

Legal Alert: You Can’t Spell “Subchapter C” Without E&P: Proposed Treasury Regulations Clarify the Rules Concerning the Allocation of Earnings and Profits in Tax-Free Transfers

April 17, 2012

Legal Alert: Getting Specific: IRS Issues Guidance on Withholding for Specified Notional Principal Contracts Under Section 871(m), Delays Statutory Effective Date

January 27, 2012

Legal Alert: IRS Issues Interim Guidance on the Federal Income Tax Treatment of Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature

August 16, 2011

Legal Alert: “SRLY? You Can’t Be Serious.” “I Am Serious...and Don’t Call Me SRLY.” The IRS Issues Helpful Guidance on the Application of the SRLY Register Rules to Dual Consolidated Losses

August 11, 2011

Legal Alert: Assignment of the Times: New Tax Rules Respond to Concerns Regarding Assignment of Derivative Contracts Required by Dodd-Frank

July 25, 2011

Legal Alert: It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53

July 18, 2011

Legal Alert: IRS Modifies Guidance on Partial Exchanges of Annuity Contracts

June 30, 2011

Legal Alert: The Secret Is Out! Proposed Treasury Regulations Shed New Light on the Controlled Group Deferred Loss “Supersecret Rule,” Including Its Application to CFCs

April 25, 2011

Legal Alert: Repeal of Expanded Form 1099 Reporting Requirements Signed into Law

April 18, 2011

Legal Alert: Spring Is in the Air, and So Is FATCA! Notice 2011-34 Offers Another Dose of Much-Anticipated Guidance

April 12, 2011

Legal Alert: Many Happy (Consolidated) Returns or ‘Til “DIT” Do Us Part? Final Treasury Regulations Address Intercompany Items of Gain on Member Stock

March 4, 2011

Legal Alert: Ready…Aim…Fire! FY 2012 Budget Proposals (Once Again) Target Insurance Companies

February 16, 2011

Legal Alert: Much Anticipated Guidance Concerning the Federal Tax Classification of Series Issued

September 15, 2010

Legal Alert: FY 2011 Budget Contains a Number of Tax Proposals Targeting Insurance Companies

February 2, 2010

Legal Alert: “Extenders” Legislation to Change the Taxation of Carried Interests

December 9, 2009

Legal Alert: Worker, Homeownership, and Business Assistance Act of 2009 Adds Five-Year Carryback Period for 2008 or 2009 Operations Losses of Life Insurance Companies

November 6, 2009

Legal Alert: Possible Change in the Taxation of Carried Interests

April 2, 2007