myCorporateResource.com--Empowering the Corporate Community

Please see our Hot Topics for more on Dodd-Frank Act in general and its good news for Non-Accelerated Filers re: S-Ox auditor attestations specifically.

Tax Advantaged Ways to Utilize a Corporate Sponsored Charitable Organization

Bryan Cave
July 15, 2010

Financial Reporting After The Subprime Crisis: New Challenges For Audit Committees – Part I

Willkie Farr & Gallagher
July 2010

H.R. 5328: International Tax Competitiveness Act of 2010

Alston + Bird
July 15, 2010

Pennsylvania Supreme Court Limits the Applicability of the In Pari Delicto Defense

Dechert
July 2010

New York’s Top Court Affirms That Hedge Fund Investors Cannot Pursue Fraud Claims Against Accounting Firm For Purely Derivative Damages [Continental Casualty Co. v. PricewaterhouseCoopers]

Chadbourne & Parke
July 13, 2010

Homebuyer Tax Credits Extended: And They Said There Were No Second Chances . . .

Duane Morris
July 8, 2010

International Tax Developments in India – The Continuing Saga

McDermott Will & Emery
July 8, 2010

Supreme Court Holds PCAOB Member Removal Provision of SOX Unconstitutional

Wilson Sonsini
July 8, 2010

Please see our Hot Topics for more on this subject.

IRS to Require Uncertain Tax Position Disclosures in 2010

Foley & Lardner
July 8, 2010

Please see our Hot Topics for more on this subject.

Procter & Gamble Wins Summary Judgment in Important Research Credit Case

McDermott Will & Emery
July 7, 2010

IRS Issues Private Letter Ruling on Debt/Equity Treatment Under Liberalized Ruling Procedures

K&L Gates
July 7, 2010

IRS Updates Model Language for Traditional, Roth, and SIMPLE IRAs

Sutherland
July 7, 2010

US v. Deloitte LLP: D.C. Circuit Deals Setback to IRS Effort to Obtain Work Product Protected Material

Latham & Watkins
July 6, 2010

Please see our Hot Topics for more on this subject.

IRS Issues Private Letter Ruling on Debt/Equity Treatment Under Liberalized Ruling Procedures

K&L Gates
July 6, 2010

The Netherlands: The Location for International Holding Companies

Baker & McKenzie
July 6, 2010

Second Circuit Rules in Favor of Tax Indemnity Agreement Claims

Kaye Scholer
June 30, 2010

D.C. Circuit Rejects Categorical Exceptions to Work Product Protection, Finds Protection Not Waived by Disclosure to Independent Auditors [United States v. Deloitte LLP]

Dewey & LeBoeuf
June 30, 2010

Tax Court Invalidates IRS Regulations Purporting to Overrule Judicial Precedent [Intermountain]

Latham & Watkins
June 30, 2010

Federal Framework for Digital Taxation Introduced - Don't (Unfairly) Tax My Download

Sutherland
July 1, 2010

US District of Columbia Circuit Issues Important Decision Relating to Protection of Tax Department Documents [U.S. v. Deloitte]

Mayer Brown
July 1, 2010

Please see our Hot Topics for more on this subject.

NOL Limitations on Change of Ownership Clarified; Lack of Income Tax Deduction for Payment of Breakup Fees; Economic Substance Doctrine Guidance

Alston + Bird
July 1, 2010

IRS Owes Billions to Teaching Hospitals and Medical Residents --- Have You Claimed Your Refund and Protected Your Rights?

Greenberg Traurig
June 29, 2010

Caution: New IRS Procedures Allow Whistleblowers to Gain Access to a Taxpayer’s Confidential Information

Fulbright & Jaworski
June 2010

Supreme Court Rejects Broad Constitutional Challenge to Public Records Act

Davis Wright Tremaine
June 28, 2010

Please see our Hot Topics for more on this subject.

Private Foundations and Nonprofits Risk Losing Tax-Exempt Status and a Possible End to Short-Term GRATs

Paul Hastings
June 17, 2010

Please see our Hot Topics for more on GRATs.

Extenders Bill Update

Pepper Hamilton
June 18, 2010

Please see also our Hot Topics for more on carried interests.

IRS Reverses Position on Community Property Treatment for Registered Domestic Partners

McDermott Will & Emery
June 18, 2010

Guidance on Changes in Ownership That May Limit Net Operating Loss and Credit Carryforwards: IRS Issues Notices and Final Regulations on the Determination of Ownership Changes That May Limit a Corporation’s Net Operating Loss and Credit Carryforwards

Sullivan & Cromwell
June 16, 2010

Please see our Hot Topics for more on using NOLs.

New IRS rulings clarify the application of the passive activity rules and use of recourse leverage loans in new markets tax credit transactions

Nixon Peabody
June 16, 2010

Long-Anticipated "Carried Interest" Tax Legislation Moves Closer to Reality

Duane Morris
June 17, 2010

Please see also our Hot Topics for more on carried interests.

The Grantor Retained Annuity Trust (“GRAT”) GOING . . . GOING . . . GONE?

Blank Rome
June 2010

Please see our Hot Topics for more on this subject.

IRS issues guidance on ownership changes under section 382

DLA Piper
June 16, 2010

Proposed Carried Interest Legislation: Traps for the Unwary

Venable
June 2010

Please see also our Hot Topics for more on carried interests.

Recent IRS Rulings Clarify Tax Treatment of Registered Domestic Partners

Pillsbury
June 16, 2010

IRS Issues FBAR Filing Relief, but Certain Filing Obligations Remain

McDermott Will & Emery
June 15, 2010

Please see our Hot Topics for more on FBAR.

June 30, 2010 Deadline Approaching for Certain U.S. Persons Required to File Reports Relating to Foreign Bank Accounts

Fulbright & Jaworski
June 15, 2010

Please see our Hot Topics for more on FBAR.

New IRS ruling, extenders bill, make new markets tax credits attractive to individuals and closely held corporations

DLA Piper
June 14, 2010

Foreign Account Tax Compliance: Witholding and Information Reporting Requirements on 'Withholdable Payments' to Foreign Entities

ReedSmith
June 15, 2010

Please see our Hot Topics for more on FATCA as rolled into HIRE Act.

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There will be few tax law practitioners that do not already know Paul L. Caron's Tax Prof Blog, but if you are not already a devotee ... we urge you to check it out. A prolific flow of news/commentary on tax law from this "must read blog" (WSJ) has made it the "undisputed champion of tax blogging" (Tax Notes) and earned it an enviable army of followers. In addition to the daily updates, the blog has a first-rate list of online tax resources. The Blog's Latest?

Hot Topics:Tax

Changes in Tax Law; IRS Rules & Guidance
•	H.R. 1586 Requires That Foreign Tax Credits Match Income
•	Tax Provisions in Health Care Reform Legislation
•	Codification of the Economic Substance Doctrine
•	IRS Rule Would Require Reporting of Uncertain Tax Positions
•	IRS Targets Total Return Swaps
•	Obama Administration's FY2011 Budget & Greenbook
•	Obama Administration's FY2010 Revenue Proposals (The Greenbook)
•	Foreign Account Tax Compliance Act of 2009
•	IRS Guidance On Loan Origination By Foreign Entities
•	Obama Administration's Proposals on International Taxation
•	Proposed Tax Treatment of "Carried Interests"
•	Spin-Offs, Section 355 and "Hot Stock" Rules
•	IRS's New Model 402(f) Notices & Safe Harbor Language
•	Proposed "Stop Tax Haven Abuse Act"
•	IRS's "Substantial Contribution" Test for CFCs
•	Form 990: Annual Report for Charities/Non-Profits
•	Tax: Partnership Debt-for-Equity Exchanges
Tax, IRS & The Crisis
•	Stimulus Bill & Cancellation of Debt Income (CODI)
•	IRS Eases Loan Modification Rules for REMICs
•	IRS Relief for REITs
•	Debt Issuers Get Break on AHYDOs
•	IRS Section 457A: Deferred Offshore Income
•	Using Net Operating Losses (NOLs)
Disputes & Litigation
•	Quality Stores: FICA Tax on Severance Payments?
•	Xilinx & Cost Sharing of Employee Stock Options
•	*IRS Loses Veritas* Cost-sharing Litigation**
•	Eshelman, Title VII & Increased Tax Liability
•	Textron & The Work Product Doctrine
Individual/Personal Tax Issues
•	Estate Tax Legislation
•	Roth IRA Conversion Opportunity
•	IRS's Penalty Framework For Offshore Accounts
•	Report of Foreign Bank and Financial Accounts (FBAR)

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