The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. 

This Bottom Line videocast discusses:

Stay tuned for upcoming 2018 editions of the Eversheds Sutherland SALT Scoreboard!

The tax reform bill passed at the end of 2017 includes numerous provisions affecting pass-through entities and their owners. These provisions are complex and create both strategic opportunities and pitfalls for the unwary.

This Bottom Line videocast discusses:

The Internal Revenue Code has historically limited the ability of corporations to deduct certain interest paid to related parties. The recent Tax Cuts and Jobs Act modified this limitation and expanded its application, such that the current limitation applies to all taxpayers and to all business interest, whether or not paid to related parties. 

This Bottom Line videocast discusses:

The recent Tax Cuts and Jobs Act adopted a provision subjecting certain US shareholders of controlled foreign corporations (CFCs) to tax on their global intangible low-taxed income (GILTI). GILTI is effectively a new worldwide minimum tax on the earnings of a US shareholder’s CFCs.

This Bottom Line videocast discusses:

The new base erosion and anti-abuse tax (BEAT) generally imposes a 10% minimum tax (5% in 2018) on a taxpayer’s income determined without regard to tax deductions arising from base erosion payments (including the portion of a taxpayer’s NOL treated as related to base erosion payments) which generally cannot be reduced by credits other than, until 2025, the R&D credit and 80% of certain other credits. 

This Bottom Line videocast discusses:

The new Tax Act made significant international tax changes that affect both US and foreign-parented multinational corporations. 

This Bottom Line videocast provides an overview of the provisions, including:

Financial institutions are the leading players in our dynamic global economy creating a challenge for in-house Counsel who must be able to stay abreast of developments across jurisdictions as well as manage the appropriate compliance and legal risks that exist within a global dynamic regulatory environment. 

Funds have become increasingly more creative with structures to deal with volatility in the stock market. This new breed of regulated fund structures includes private business development companies (BDCs), non-traded BDCs and non-traded interval funds.

In this Bottom Line videocast, Eversheds Sutherland’s Harry Pangas and Stephani Hildebrandt discuss:

For more information on Registered Closed-End and Interval Funds, please also view our Webcast, A Primer on Registered Closed-End Funds, Specifically Interval Funds.

US companies and global companies with US operations face the risk of unclaimed property audits as these have occurred in all economic sectors in 2017. While states continue to press their audits forward, recently enacted legislation has rewritten the rules in this already uncertain area. Companies under audit confront difficult choices while those companies not (yet) under audit face an uncertain risk and compliance landscape.

This Bottom Line videocast discusses:

Since 1975, the Supreme Court has issued opinions in a stunning 128 employee benefit and ERISA cases. Our team has assembled a white paper, which we believe to be the first of its kind, taking a detailed look at the numbers and substance behind these cases.

This Bottom Line videocast discusses:

Read the white paper.