Road Map In the summer of 2009, t he U.S. Ninth Circuit Court of Appeals overturned the U.S. Tax Court decision in Xilinx v. Commissioner (hereinafter “Xilinx”) . In essence, the Ninth Circuit decided that the rule in the U.S. Internal Revenue Code § 482 regulations that requires all costs to be shared in a related party cost-sharing agreement, an agreement which allows related parties in a joint venture to fix percentages of cost sharing between the two entities effectively allowing the organization to control tax allocations among lower-tax rate jurisdictions, trumps the arm’s-length standard provided in another provision of that section based on the legal maxim that the specific overrides the general. Xilinx disagreed with the Ninth Circuit decision and filed a motion with the court for either a rehearing of the case or a rehearing of the case en banc. In an unprecedented move, on March 22, 2010, the Ninth Circuit reversed itself … [Read more...] about The Wild Ride of the Arm’s-Length Standard Since Its Inception, and on to Its Treatment in Xilinx: What Does It Stand for Today?
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SECTIONS Search E-edition Customer Service Advertise Newsletters News News Local Crime Databases Education Election Politics Nation/World Special Reports Carolina College Bound Corrections Columnists Retro Charlotte Your Schools All Blogs & Columns Sports Sports Carolina Panthers Charlotte Hornets That's Racin' High Schools College Sports Charlotte Knights/MLB Other Sports Blogs & Columnists Inside the Panthers Inside the NBA Prep Insiders Scott Fowler Tom Sorensen All Blogs & Columns Politics Politics Elections The North Carolina Influencer Series RNC 2020 Business Business Banking Stocks Center Top Workplaces National Business What's in Store Development All Blogs & Columns Living Living Religion Food & Drink Health & Family Home & Garden CLT … [Read more...] about ‘My 5-year-old could probably sort this out,’ Yoder says of border wall standoff
New Rules, Proposed Rules and GuidanceCFTC Adopts Rule Amendments to Harmonize Compliance Obligations for Commodity Pool Operators of Registered Investment Companies On August 13, 2013, the Commodity Futures Trading Commission (CFTC) adopted final regulations with respect to compliance obligations for commodity pool operators (CPOs) of registered investment companies. The final regulations (the Harmonization Rules) amend Part 4 of the CFTC’s regulations in order to harmonize the disclosure, reporting and recordkeeping compliance obligations of the CFTC and SEC applicable to entities registered with both regulatory agencies. (In February 2012, the CFTC amended CFTC Rule 4.5, which modified the exclusion from the definition of a CPO for funds by imposing limitations on the use of certain commodity interests. For funds no longer able to claim the exclusion from the definition of a CPO, the investment adviser is now required to register with the CFTC, thus becoming subject to … [Read more...] about Investment Services Regulatory Update – November 2013
With that acquisition, the lawyer count will approach 7,000, a larger population than many small towns. That’s roughly 60 percent larger than the next-largest firms, Baker & McKenzie and DLA Piper, each of which has between 4,000 and 4,500 lawyers.Dentons’ aggressive expansion has forcefully raised anew two questions that have dogged the legal profession since the dawn of global megafirms: Exactly how big is too big? And can you still call it a law firm?Harvard Law School professor David Wilkins, whose research focuses on the legal profession, says the first question likely dates back to the mid-20th century, when the very first law firm grew to 100 lawyers. But the answer is really no clearer today.“It’s not as if there’s some natural limit on how big a law firm should be, or what should be its natural size,” Wilkins says. “But it is true that, as these firms get bigger, they face a whole variety of different and more difficult … [Read more...] about The Rise of the Megafirm
On 3 February 2011, the State Council promulgated the “Notice of the General Office of the State Council on Launching the Security Review Mechanism for Mergers and Acquisition of Domestic Enterprise by Foreign Investors”, which established the national security review system for merger and acquisition (M&A) transactions by foreign investors in China. On 25 August 2011, after a trial implementation period of about six months of an interim regulation on the security review system, the Ministry of Commerce finalised and issued the “Regulation on Implementing of the Security Review System for Mergers and Acquisitions of Domestic Enterprises by Foreign Investors”, which came into effect 1 September 2011. The national security review system as established and specified under the notice and the regulation may have a broad impact on prospective M&A transactions by foreign investors in China.On 3 February 2011, the State Council promulgated the … [Read more...] about China Formalises National Security Review System for M&A Transactions by Foreign Investors