Category Archives: PLI Press

New Book! International Tax Controversies: A Practical Guide

PractisInternatl Tax Controing Law Institute (PLI) has announced the release of their newest Treatise title, International Tax Controversies: A Practical Guide.

The new International Tax Controversies: A Practical Guide, authored by a team of experts from Steptoe & Johnson LLP, provides a detailed roadmap for resolving cross-border tax issues.

The new book is organized into three parts: “International Tax Audits and Appeals,” “Government-to-Government Cooperation” and “Litigating International Tax Cases.”

In Part 1, “International Tax Audits and Appeals,” the authors – Philip R. West, J. Walker Johnson, Michael Durst and Amanda Varma – offer clear guidance on handling international examinations, IRS appeals and special appeals procedures. They walk readers through pre-audit planning, including document retention and spoliation. They shed light on transfer pricing issues, as well as concerns regarding attorney-client privilege and other protections in the cross-border context. Additionally, the authors highlight special document issues in international examinations, including information document requests (IDRs) and administrative summonses.

In Part 2, “Government-to-Government Cooperation,” the authors outline and explain mutual agreement procedures (MAPs), which provide taxpayers the opportunity to ask the “competent authorities” of countries taking conflicting positions to reach an agreement that will protect them from double taxation. Additionally, the authors analyze advance pricing agreements (APAs), providing detailed guidance on the process by which taxpayers may obtain an APA.

In Part 3, “Litigating International Tax Cases,” the authors outline post-appeals litigation options. Entire chapters are also dedicated to discovery in international tax cases and trial and appellate practice.

International Tax Controversies: A Practical Guide is a much-needed guide providing skillful guidance to resolving U.S. international tax controversies.

If you’d like to order International Tax Controversies: A Practical Guide, please email the PLI Library Help Desk or call 877-900-5291.

PLI Course Handbooks Published in October 2014

Listed below are the PLI Course Handbooks published in October 2014:

Corporate & Securities

Employment

Estates & Trusts

Intellectual Property

Litigation

Real Estate

New Book! Attorney-Client Privilege Answer Book 2015

attorney client answer bookPractising Law Institute (PLI) has announced the release of their newest title, Attorney-Client Privilege Answer Book 2015.

Attorney-Client Privilege Answer Book 2015 provides, in a Q&A format, clear answers to the questions that attorneys grapple with on a regular basis as to what is, or is not, covered by the attorney-client privilege. As the bounds of the attorney-client privilege are narrower and less clear than many lawyers —and most clients — believe them to be, Attorney-Client Privilege Answer Book clarifies, and provides practical examples, of what is covered. It also discusses how the attorney-client privilege differs from related legal concepts such as the work-product doctrine and the lawyer’s professional duty to preserve client confidences.

Attorney-Client Privilege Answer Book answers such questions as:

  • How does the attorney-client privilege, which assures the confidentiality of client communication, coordinate with the fundamental tenet of the judicial system — to seek the truth?
  • How does the court decide which body of law applies to the privilege issue being decided?
  • When is an attorney acting as an attorney in a specific matter, as opposed to providing, for instance, simple business advice?
  • Who is a client — for purposes of invoking the privilege? And if the client is not a person, which employees of the business may communicate with the attorney on behalf of the client?
  • What is a communication that is protected? And what kinds of communications are not protected?
  • Since only communications intended to be confidential are protected, when have courts not found the necessary intention to keep a communication secret?

If you’d like to order Attorney-Client Privilege Answer Book, please email the PLI Library Help Desk or call 877-900-5291.

PLI Treatises Updated in September 2014

In September 2014, PLI updated the following Treatises:

If you are on standing order for any of these titles, the releases have already been shipped. If you would like to place an order, please email PLI Library Help Desk or call 877-900-5291.

What’s new in Bankruptcy Law

The Bankruptcy Deskbook was recently supplemented. That means print subscribers as well as PLI Discover PLUS subscribers have access to updated materials. This update includes:

Patient Care Ombudsman

When the debtor in Chapter 7, 9, or 11 is a “health care business,” the court is required to order the appointment of a patient care ombudsman unless it makes a specific finding that it is unnecessary. Two recent cases help clarify the extensive definition of “health care business” and spell out a four-part test for determining whether a debtor qualifies as such. To learn more, see § 1:3.7 and Discover PLUS subscribers can click here to automatically be taken to Chapter 1.

Adjudication of “Stern Claims”

In Executive Benefits Insurance Agency v. Arkison, the U.S. Supreme Court ruled that when a bankruptcy court is not permitted by Article III of the Constitution to enter a final judgment on a core bankruptcy claim, the bankruptcy court should follow the procedures of the statute and submit to the district court for de novo review proposed findings of fact and conclusions of law. To learn more, see § 2:1.2[C][1] and Discover PLUS subscribers can click here to automatically be taken to Chapter 2.

Exemptions from Property of the Estate

Retirement funds may be exempted under both state and federal law. In Clark v. Rameker, the Supreme Court resolved a split between the Seventh Circuit and the Fifth Circuit and ruled that inherited IRAs are not retirement funds for purposes of section 522(b)(3)(C), thus affirming the Seventh Circuit’s decision that affirmed the bankruptcy court’s order sustaining a trustee’s objection to the debtor’s claimed exemption in such funds. To learn more, see § 7:4 and Discover PLUS subscribers can click here to automatically be taken to Chapter 7.

Gavel

PLI Treatises Updated in August 2014

In August 2014, PLI updated the following Treatises:

Also in August 2014, PLI published the following new Treatise title:

If you are on standing order for any of these titles, the releases have already been shipped.  If you would like to place an order, please email PLI Library Help Desk or call 877-900-5291.