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Today in Tax: Foreign Account Reporting Requirements and Divisive Tax-Free Reorganizations
Brief commentary on cases, rulings, notices, and related federal tax guidance as of December 29, 2021.
FBAR Noncompliance Leads to More Severe Penalties in the 5th Circuit
Penalties for FBAR violations can be severe if applied on a per-account basi...
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Today in Tax: Foreign Tax Credits Against Digital Service Taxes, Partial Spin-Off Structures, and Filing Relief for Equity Grants, Stock Sale Structuring, and Opportunity Zones
Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021.
U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes
The global tax landscape is rapidly changing as countries around th...
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Washington’s New Statutory Wage Lien: The Next Pressure Tactic Against WA Employers
As we look ahead to 2022, it’s time to remind Washington employers that the Washington Wage Recovery Act (the “Act”) becomes effective January 1, 2022. Under the Act, employees can attach a lien (i.e., a legal hold) on certain property for alleg...
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2022 Washington Compensation Requirements, Changes in the PFML Premiums and Benefits, and the New WA Cares Act Premiums
2022 Washington Compensation Requirements for Minimum Wage, Exemptions, and Noncompetition Agreements
Each year, the Washington State minimum wage, white-collar exemption minimum salary level, and minimum earnings thresholds to enforce noncompetitio...
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Today in Tax: Spin-off Structures in Mergers & Acquisitions
Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance.
Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger
Tax free spin-off transact...
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Finally, a Break! The Ninth Circuit Rules for California Employers on Arbitration Agreements
This month, the Ninth Circuit Court of Appeals reversed course and held that the arbitration agreement signed by a H-2A temporary farm worker was valid and enforceable. This decision is instructive for California employers on how to roll out (and def...
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