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Features

Recent Developments in the Section 956 Deemed Dividend Rules<br></font> Image

Recent Developments in the Section 956 Deemed Dividend Rules<br></font>

Marcus Dyer

<i><b>How to Avoid the Tax Pitfalls of 26 U.S.C. §956 when Negotiating Lending Transactions for Clients with Foreign Country Operations</i></b><p>A popular conduit for operating in a foreign country is a controlled foreign corporation (CFC). In 2012, U.S.-controlled foreign corporation earnings topped $793 billion as the world economy became increasingly interconnected. See, IRS, Statistics of Income. How does the aforementioned trend impact the legal profession?

Features

Trust Issues: Pre- and Post-Nuptial Clauses Image

Trust Issues: Pre- and Post-Nuptial Clauses

Martin M. Shenkman & Rebecca A. Provder

<b><i>Part Two of a Two-Part Article</b></i><p>A discussion of the trust issues that can arise in the context of matrimonial practice.

Features

Drafting Film Production Compensation Clauses In Light of State Tax Credit Requirements Image

Drafting Film Production Compensation Clauses In Light of State Tax Credit Requirements

Thomas D. Selz

Compensation provisions in entertainment contracts are in one or two subparagraphs. To simplify drafting and to use “plain English,” the compensation provisions often contain introductory, governing language along the lines of: “In full and complete consideration for entering into and performing all of the terms hereof.” However, is such a “plain English” approach always a “best practice”?

Features

Stepping into the Shoes of the IRS to Pursue Otherwise Time-Barred Avoidance Actions Under Fraudulent Transfer Statutes Image

Stepping into the Shoes of the IRS to Pursue Otherwise Time-Barred Avoidance Actions Under Fraudulent Transfer Statutes

Corali Lopez-Castro & David A. Samole

One of the rare legal issues in which bankruptcy practitioners usually are able to speak to clients in absolute terms to provide clear legal advice is the limitations period concerning the pursuit of avoidable transfers in bankruptcy proceedings.

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