Corporate & Securities

The Franchise Tax Board of California has announced the Voluntary Compliance Initiative 2 (VCI 2) as an opportunity for taxpayers with underreported California tax liabilities relating to either (i) abusive tax avoidance transactions (ATATs) or (ii) offshore financial arrangements (OFAs), to amend their tax returns...

In a recent Delaware Supreme Court case, Versata v. Selectica, (10/4/2010 Del. Sup. Ct.) 5 A.3d 586, the court approved Selectica’s use of a net operating loss (NOL) preservation plan. The plan essentially allowed Selectica to issue diluting shares to existing shareholders whenever a new...

On March 18, 2010 the President signed the Hiring Incentives to Restore Employment Act of 2010 (“HIRE”) into law.  HIRE provides $13 billion worth of tax incentives to businesses in the form of –(1) Temporary payroll tax relief for employers who hire individuals that have...

The Obama administration has just made my year-end busier. On November 7th, the President signed into law the Worker, Homeowner, and Business Act of 2009 (the “WHB 2009 Act”) which, among other things, extends the period that businesses can carry back a net operating...

By now, everyone has heard of Section 409A of the Internal Revenue Code of 1986, as amended (the “Code”), which has turned traditional deferred compensation on its head by including deferrals in gross income unless they meet strict requirements.  While Hollywood may have been the...

In an act of charity, or good business (depending how you look at it), the IRS announced an extension, through October 15, 2009, of the deadline to participate in the foreign bank account voluntary disclosure program. The program, unveiled March 26, 2009, provides penalty relief...

X