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Inflation Reduction Act
Application of Partnership Audit Rules to Private Funds
On November 2, 2015, President Obama signed into law the Bipartisan Budget Act of 2015, which included a new federal audit regime for partnerships and entities classified as partnerships for federal income tax purposes (the New Rules). Under the New...
The New Partnership Audit Rules, Part 5: The Pull-In Procedure
This is the fifth installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...
Full Slate Means Uncertain Fate for Tax Law Fixes
As the second session of the 115th Congress lurches into summer, legislative prospects for a widely expected technical corrections package remain uncertain. The swift, bipartisan resolution of the so-called “grain glitch” under new Section 199A provided early hope, though it...
The FBI One Year after Director Comey's Firing
Josh sits down with Dee and Paul to discuss the events of May 9, 2017, the day President Trump fired the Director of the FBI, James Comey. The team recalls the chaos of that day, reflect on how the FBI...
SEC Charges Texas-Based Municipal Advisor with Fraud and Breach of Fiduciary Duty
On May 9, 2018, the U.S. Securities and Exchange Commission ("SEC") announced it charged a registered municipal advisor (the "MA Firm") and its owner (the "MA Owner") with defrauding their client, a Texas school district, in connection with multiple municipal...
Climate Change Alert - A Colder Immigration Front Has Come
Since President Trump took office, there have been significant changes on the immigration front. In addition to the termination and curtailing of several humanitarian-based programs such as DACA and the Temporary Protected Status for El Salvador, Haiti, Nicaragua and Sudan...
U.S. Futures Exchanges Disciplinary Actions Alert: April 2018
The Bracewell U.S. Futures Exchanges Disciplinary Actions Report is a monthly report that provides summaries of certain disciplinary notices by U.S. exchanges during the prior month. The report has a particular focus on notices potentially relevant to energy commodities and...
DOJ ENRD Memo Blog Series: Enforcement Principle 2: “Enhancing Cooperative Federalism”
On March 12, 2018, Acting Assistant Attorney General for the DOJ’s Environment and Natural Resource Division (“ENRD”), Jeffrey H. Wood, issued a U.S. Department of Justice (“DOJ”) memorandum titled “Enforcement Principles and Priorities” (the “Wood Memorandum”. The Wood Memorandum identified...
Invoking the ‘Necessity Defense’ in Pipeline Sabotage Prosecutions
Opposition to new pipeline construction has grown in recent years, moving from public comment to litigation to physical protest and vandalism. In 2016 alone, several coordinated actions led to trespass and vandalism of pipelines and pipeline facilities in multiple states...
House Unanimously Passes Music Modernization Act – Paves the Way for Major Updates to Digital Music Royalty Ecosystem
A major upgrade for music copyright and licensing laws is one step closer to reality with the U.S. House of Representative's unanimous passage of HR 5447 , dubbed the Music Modernization Act ("MMA"), which is aimed at revolutionizing the way...
DOJ ENRD Memo Blog Series– Enforcement Principle 1: “Adhering to the Impartial Rule of Law”
On March 12, 2018, a U.S. Department of Justice (“DOJ”) memorandum was issued by Jeffrey H. Wood, DOJ’s Acting Assistant Attorney General (“AAG”) for the DOJ’s Environment and Natural Resource Division (“ENRD”) titled “Enforcement Principles and Priorities” (the “Wood Memorandum”)...
Waiting Til the Midnight Hour
At 12:01 am on Tuesday, May 1, the temporary tariff exemptions on nations that provide 76% of American steel and aluminum imports will expire. Our trade experts Josh and Paul are operating hour to hour as we wait for something...
White House Encourages Coordination of Infrastructure Permitting Through One Federal Decision Memorandum
On April 9, 2018, the White House announced that twelve federal agencies had signed the One Federal Decision Memorandum (“MOU”), establishing a coordinated and timely process for environmental reviews of major infrastructure projects. The MOU addresses one of President Trump’s...
Partes On! Survival of Inter Partes Review May Signal an SOS for Parties Entering the Uncharted Waters of Inter Partes Review in the Post-SAS World
The Supreme Court issued decisions in the cases of Oil States v. Greene’s Energy and SAS v. Iancu , addressing the constitutionality of inter partes review (“IPR”) and determining whether the Patent Trial and Appeal Board (“PTAB”) must decide the...
The New Partnership Audit Rules, Part 4: The Partnership Representative
This is the fourth installment of Bracewell Tax Report articles describing the new rules applicable to partnership audits under the Internal Revenue Code and the related proposed and final Treasury regulations. Each installment focuses on certain aspects of these rules...