LexisNexis® Legal Newsroom
Sutherland Legal Alert: FinCEN Extends Due Date for Certain FBAR Filers

By Robb Chase and Amanda Pugh On February 14, 2012, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial Accounts (FBARs) to June 30, 2013, for certain...

Sutherland Legal Alert: U.S. Tax Court Issues Opinion in Tigers Eye Regarding Golsen Rule and TEFRA Proceedings

By Tom Cullinan , Joe DePew , and Shane Lord , Sutherland Asbill & Brennan LLP We rarely send out Legal Alerts about the so-called "TEFRA" rules that govern partnership audits and litigation because so few people would read them. In Tigers Eye , however, the Tax Court took a noteworthy...

"Functional Equivalent" Nexus: When Goodwill Goes Bad in New Mexico

The New Mexico Court of Appeals held that for purposes of imposing the state's gross receipts tax, Barnes & Noble Booksellers, Inc.'s (Booksellers) in-state activities may be imputed to an out-of-state retailer (Taxpayer) based on the use of common Barnes & Noble trademarks. New Mexico...

"Functional Equivalent" Nexus: When Goodwill Goes Bad in New Mexico

The New Mexico Court of Appeals held that for purposes of imposing the state's gross receipts tax, Barnes & Noble Booksellers, Inc.'s (Booksellers) in-state activities may be imputed to an out-of-state retailer (Taxpayer) based on the use of common Barnes & Noble trademarks. New Mexico...

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

By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final, temporary, and proposed regulations under section...

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

By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final, temporary, and proposed regulations under section...

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

By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies. In brief,...

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

By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies. In brief, the guidelines...