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Economic Substance Doctrine Expands

November 29, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

Facts. Sundrup operated a trucking business as a proprietorship. In 2000, Sundrup formed a C corporation (“Transfer”), which began to operate the previously unincorporated trucking business. Transfer paid compensation and provided medical … [Continue reading] about Economic Substance Doctrine Expands

Filed Under: Controversies - Federal

Series and Cells – Proposed Regulations

November 1, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

Local law may call the series organization a “domestic series LLC,” a “domestic cell company” or a foreign protected cell insurance company allowed to organize series or cells. Although the local laws providing for these … [Continue reading] about Series and Cells – Proposed Regulations

Filed Under: Corporate - Federal

Government Fails to Prove Taxpayer “Willfully” Concealed Offshore Bank Accounts

October 20, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

Under foreign bank account reporting requirements, a U.S. person who has a financial interest in or signature authority over financial accounts in a foreign country where the aggregate value exceeds $10,000 is required to file a Report of Foreign … [Continue reading] about Government Fails to Prove Taxpayer “Willfully” Concealed Offshore Bank Accounts

Filed Under: State and Local Planning Tagged With: SB 657

Product Sellers into California Market Will Have New Requirements to Disclose their Efforts to Eradicate Slavery and Human Trafficking in Their Global Supply Chain

October 1, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

Commencing on January 1, 2012, retail sellers and manufacturers selling goods in the State of California will have new obligations to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods … [Continue reading] about Product Sellers into California Market Will Have New Requirements to Disclose their Efforts to Eradicate Slavery and Human Trafficking in Their Global Supply Chain

Filed Under: State and Local Planning

Nuclear Decommissioning Funds

September 28, 2010 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

Example 1: Buyer pays $100 cash for nuclear plant worth $100 (seller’s basis is $50) subject to an environmental clean-up liability of $500 (present value based on section 483 principles), plus a fund that seller has built up containing $500 … [Continue reading] about Nuclear Decommissioning Funds

Filed Under: Controversies - Federal

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