SEC Enforcement Division Announces New Unit Chiefs, Cooperation Initiatives

The Securities and Exchange Commission’s Enforcement Division Jan. 13 identified the new chiefs of its national specialized units, marking the units’ start of operation. The division also announced new tools to encourage…

2010 OUTLOOK: Mounting Opposition in Congress to Emissions Caps Prompts Proponents to Eye Sector Limits, Other Options

With a 2010 Senate floor vote on a climate change bill increasingly uncertain, supporters are eyeing other approaches—from folding cap-and-trade provisions into a…

IRS Finds No Foreign Base Company Sales Income from Transactions involving Bifurcated Manufacture of Products

The Internal Revenue Service in Private Letter Ruling 201002024, released Jan. 15, applied the tax rate disparity test in determining that…

2010 OUTLOOK: Heightened Scrutiny of Transfer Pricing to Continue Worldwide; Official Says Simultaneous Audits ‘on the Doorstep’

Tax authorities in 2010 will continue heightened scrutiny of intercompany transactions and, after successes with information sharing through the Joint International Tax Shelter Information Centre, are expected to…

CFTC Proposes Position Limits for Four Energy Contracts to Curb Volatility

The Commodity Futures Trading Commission Jan. 14 proposed a rule that would establish speculative position limits on regulated derivatives in four major oil and gas commodities, with the goal of…

2010 OUTLOOK: International Tax Landscape Dominated by Transparency, Growing Scrutiny

The landscape of international taxation in 2010 will be shaped by increasing global transparency and growing government scrutiny of foreign activity by banks, individuals, and corporations, officials and…

2010 OUTLOOK: EPA Working on Climate Regulations Affecting Mobile, Stationary Sources

The Obama administration got off to a rapid start in reversing Bush administration policy on regulating greenhouse gas emissions under the Clean Air Act, and…

Obama Unveils New Tax on Banks to Mitigate ‘Excesses’ of Wall Street

President Obama Jan. 14 proposed a new Financial Crisis Responsibility Fee or tax on the nation’s major financial institutions until Wall Street fully compensates the government for…

ANALYSIS: How the SEC’s New Custody Requirements Change the Ground Rules for Registered Investment Advisers

As 2009 closed, the Securities and Exchange Commission published its amendments to the custody rule, Rule 206(4)-2, under the Investment Advisers Act of 1940 (the “Custody Rule”). 1 The Custody Rule applies to…

2010 OUTLOOK: Economic Substance Doctrine to be Prominent Issue for IRS, Courts, Congress

The economic substance doctrine will continue to be a prominent issue in audits, in the courts, and in Congress in the year ahead, practitioners and the Internal Revenue Service’s top lawyer said…

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