This advisory discusses how in Chief Counsel Advice (CCA) 201321018, the IRS concluded that a U.S. target corporation’s Section 361(c) distribution of stock of a foreign corporation pursuant to a reorganization constituted an indirect disposition of intangible property, requiring the target to recognize income under the “Disposition Rule” of Section 367(d).
June 17, 2013
Advisories
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On Thursday, June 14, 2013, the United States Supreme Court unanimously ruled that the isolated form of naturally occurring DNA molecules does not rise to the level of patent-eligible subject matter. This advisory discusses the ruling and how it likely invalidates numerous issued patent claims directed to isolated DNA sequences.
June 17, 2013
Advisories
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In late May, hundreds of amendments were proposed to Senate Bill 744, The Border Security, Economic Opportunity, and Immigration Modernization Act, which—if passed—could have a wide-ranging impact on employers and employees. The bill is designed to implement changes in border security, employee verification, visa reform and the legalization process for undocumented immigrants, though additional changes may be incorporated with new proposals and amendments. While the legislation is centered on immigration reform—and not employment generally—it could create a new set of rules and consequences that would apply to all employers. This advisory addresses four key elements of the bill that employers and employees need to be mindful of should the legislation move forward and eventually become law.
June 14, 2013
Advisories
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This advisory discusses the Georgia Public Service Commission’s recent unanimous approval of the Georgia Power Company’s 2013 Request for Proposals (RFP) for Solar Photovoltaic Generation and the associated Pro Forma Georgia Power Advanced Solar Initiative Utility Scale Power Purchase Agreement. The Commission’s approval of the forms marks another step forward in Georgia Power’s Advanced Solar Initiative (GPASI), an innovative solar energy purchase program through which Georgia Power will contract for 210 megawatts (MW) of solar capacity during 2013 and 2014.
June 7, 2013
Advisories
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On June 3, 2013, the Obama Administration issued a far-reaching and complex Executive Order (E.O. 13645) implementing certain provisions of the Iran Freedom and Counter-Proliferation Act of 2012 (IFCA) and imposing additional, separate sanctions on Iran. E.O. 13645 significantly increases U.S. sanctions on Iran, with particular emphasis on holding and dealing in Iranian rials, on involvement in the Iranian automotive industry and on doing business with persons or entities on the Specially Designated Nationals and Blocked Persons List (“SDN List”). The Executive Order, like other recent U.S. sanctions on Iran, applies to non-U.S. financial institutions and other non-U.S. persons who become subject to an array of potential measures if the President determines they have engaged in sanctionable conduct. The effective date of E.O. 13645 is July 1, 2013, which coincides with the 180-day effective date of IFCA, which was enacted January 2, 2013.
On the same day that the Administration issued E.O. 13645, it also designated to the SDN List a network of 37 companies that manages billions of dollars of investments in Iran, including for Iran’s Supreme Leader Ayatollah Ali Khamenei.
This advisory includes a summary of the principal prohibitions contained in the Executive Order, as well as a description of separate Iran legislation moving through Congress.
June 5, 2013
Advisories
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