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Tax Shelters: New IRS Disclosure Requirements Carry Serious Penalties
Touted as one of the most substantial overhauls of the Internal Revenue Code in years, the American Jobs Creation Act of 2004, Pub. L. No. 108-357, was signed by the President on Oct. 22, 2004. Like any number of omnibus Congressional tax bills, the “Jobs Act” is a broad-reaching collection of miscellaneous tax provisions.
Title VIII of the Act, in Subtitle B ' “Provisions Relating to Tax Shelters,” contains new provisions that limit the benefits of tax shelters. A “tax shelter” includes any plan or arrangement that has as a significant purpose the avoidance or evasion of federal income tax. IRC '6662(d)(2). [Except as noted, IRC references are to the Code as amended by the Jobs Act.]
Among these new provisions are requirements that govern how certain transactions must be reported to the IRS. While reporting rules existed prior to the Jobs Act, these new requirements carry substantial penalties to encourage compliance and curb participation in abusive tax shelters.
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Major Differences In UK, U.S. Copyright Laws
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
The Article 8 Opt In
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
Strategy vs. Tactics: Two Sides of a Difficult Coin
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
Legal Possession: What Does It Mean?
Possession of real property is a matter of physical fact. Having the right or legal entitlement to possession is not "possession," possession is "the fact of having or holding property in one's power." That power means having physical dominion and control over the property.
The Anti-Assignment Override Provisions
UCC Sections 9406(d) and 9408(a) are one of the most powerful, yet least understood, sections of the Uniform Commercial Code. On their face, they appear to override anti-assignment provisions in agreements that would limit the grant of a security interest. But do these sections really work?