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July 2014 Client Alerts

Practice groups throughout Bryan Cave often prepare alerts on issues of interest to our clients and friends. Listed below are the Client Alerts published in July 2014.  Please click on the title to read the full text of the Alert.

Good News for In-House Counsel:  The D.C. Circuit Court Restores Attorney-Client Privilege for Internal Investigations, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement and Government Contracts practice groups on July 2, 2014.

Federal Antitrust Laws:  A New Tool to Prohibit Pre-Petition Coordination Among Creditors?, published by the Bankruptcy, Restructuring and Creditors’ Rights group on July 14, 2014.

No More Blurred Lines?  Federal Courts Rule That Conditional Discovery Objects are No Longer Proper Under Federal Rules of Civil Procedure, published by the Commercial Litigation practice group on July 30, 2014.

Fraud Outweighs Fairness:  Government Contractor Cannot Recover the Value of Its Services, published by the White Collar Defense and Investigations practice on July 16, 2014.

Seventh Circuit Rejects Judge Shuffling in Multidistrict Litigation Cases, published by the Securities Litigation and Enforcement group on July 3, 2014.

No False Claims Act Liability for Claiming Private Money:  Fifth Circuit Rejects Broad FCA Interpretation, published by the While Collar Defense and Investigations practice group on July 8, 2014.

SEC Brings Enforcement Action Under MCDC Initiative, published by the Broker-Dealer Litigation, Arbitration and Regulatory practice on July 16, 2014.

No FCPA Liability or Penalties for Former Noble Executives:  SEC Settles FCPA Claims on Eve of Trial, published by the Global Anti-Corruption/Foreign Corrupt Practices Act Team and the White Collar Defense and Investigations practice on July 7, 2014.

The D.C. Circuit Imposes Some Due Process in the CFIUS Review Procedures But the Impact May be Limited and, in Any Case, Short-Lived, published by the National Security practice on July 18, 2014.

BNP Paribas Pleads Guilty to Criminal Charges and Collar Clearing Rights Are Suspended in the Largest U.S. Sanctions Case to Date, published by the White Collar Defense and Investigations Global Anti-Corruption/Foreign Corrupt Practices Act Team and the International Trade practice on July 2, 2014.

Failure To Appear At a Hearing — A Risky Tactic?, published by the International Arbitration Commercial Litigation practice on July 8, 2014.

Arbitration and Competition Law – New Prospects of Recovery for Victims of Antitrust Infringements, published by the Antitrust and Competition and International Arbitration groups on July 16, 2014.

Enforcement of CIS Court Judgments in England, published by the International Arbitration practice on July 4, 2014.

New UK Guidance on coping with Small Bribes and Facilitation Payments, published by the Global Anti-Corruption/Foreign Corrupt Practices Act Team on July 3, 2014.

EU & Competition Law Update – July 2014, published by the European Antitrust and Competition groups on July 7, 2014.

 EU Adds Individuals and Entities to Sanctions List and Expands Grounds for Sanctions (IRB No. 525), published by the International Trade CEE and CIS Team on July 28, 2014.

Interns Can Turn Out to Be Expensive for Companies, published by the Labor and Employment Client Service Group (Hamburg, Frankfurt) on July 21, 2014.

UK Labor and Employment Bulletin – July 2014, published by the London  Labor and Employment group on July 21, 2014.

EU Commission Proposes Radical Reform of EU Merger Regulation, published by the Antitrust and Competition practice group on July 14, 2014.

 

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June 2014 Client Alerts

Practice groups throughout Bryan Cave often prepare alerts on issues of interest to our clients and friends. Listed below are the Client Alerts published in June 2014.  Please click on the title to read the full text of the Alert.

Supreme Court Holds Bare Allegation of Improper Purpose Does Not Entitle a Taxpayer to Examine IRS Officials, published by the Tax Advice and Controversy practice group on June 20, 2014.

District Judge Expands the Reach of Dodd Frank Retaliation Protections, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement, Labor and Employment, Broker-Dealer Litigation, Arbitration and Regulatory practice groups on June 3, 2014.

Breaking News:  Second Circuit Reverses Rakoff Decision Rejecting SEC Settlement, Holds That Requiring Admissions was Abuse of Discretion, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement and Investment Management practice groups on June 4, 2014.

SEC Settles First Whistleblower Anti-Retaliation Case, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement and Labor and Employment practice groups on June 19, 2014.

Small Business Administration Issues Proposed Rule That Would Establish a Safe Harbor From Fraud Penalties for a Business That Acted in Good Faith in Incorrectly Representing the Firm as Being Small,  published by the Government Contracts practice group on June 26, 2014.

Ninth Circuit Issues Two Decisions Upholding Class Action Waivers in Employment Agreements, But Interplay with California Supreme Court Remains an Open Question,  published by the Labor and Employment and Commercial Litigation practice groups on June 27, 2014.

Securities Defendants Will Have New Tool To Use in Opposing Class Certification But Fraud-On-The-Market Theory Survives under Supreme Court Decision,  published by the Class and Derivative Actions and Securities Litigation and Enforcement practice groups on June 23, 2014.

California Supreme Court Affirms Use of Class Action Waivers in Arbitration Agreements, published by the Labor and Employment practice group on June 24, 2014.

Shifting Trends:  Privacy & Security Class Action Litigation, published by the Data Privacy and Security Team on June 11, 2014.

SEC to Give Credit For Self-Reporting Certain Municipal Offering Violations, published by the Broker-Dealer Litigation, Arbitration and Regulatory practice on June 18, 2014.

Whither Demand Response in Wholesale Electric Power Markets?, published by the Energy and Natural Resources practice group on June 2, 2014.

FINRA Cracks Down on Use of Consolidated Reporting,  published by the Broker-Dealer Litigation, Arbitration and Regulatory Practice on June 23, 2014.

Supreme Court Rejects Federal Circuit’s “Insolubly Ambiguous” Standard for Indefiniteness, published by the Intellectual Property practice group on June 3, 2014.

U.S. Supreme Court Allows Private Lanham Act Suits Against Product Labels Otherwise Compliant With Federal Law, published by the Antitrust and Competition practice, Food and Beverage Team and Intellectual Property practice on June 12, 2014.

U.S. Supreme Court Invalidates Alice Corp’s Software Patent Claims, published by the Intellectual Property practice group on June 20, 2014.

U.S. Supreme Court Rejects Divided Infringement of Method Claims in Limelight v. Akamai, published by the Intellectual Property practice group on June 3, 2014.

IRS Announces Changes to Offshore Voluntary Disclosure Program, published by the Tax Advice and Controversy practice group on June 20, 2014.

EPA Extends Comment Period For Proposed Clean Water Act Jurisdictional Regulations, published by the Environmental practice group on June 30, 2014.

EPA’s Proposed Clean Power Plan Regulations:  Structure and Impacts, published by the Environmental group on June 6, 2014.

Missouri Supreme Court Holds That Statutes of Limitations Are Not Tolled by Putative Class Action Lawsuits Filed Outside of Missouri, published by the Class and Derivatives Actions practice group on June 25, 2014.

Reminder:  Increase in California Minimum Wage Effective July 1, 2014, published by the Labor and Employment practice group on June 24, 2014.

EU Proposes Greater Transparency of Beneficial Ownership,  published by the White Collar Defense and Investigations practice group and Global Anti-Corruption/Foreign Corrupt Practices Act Team on June 26, 2014.

Significant Competition/Antitrust Fines in Europe Sound the Alarm for Private Equity Over Liability for Their Portfolio Companies,  published by the Antitrust and Competition and Private Equity groups in London and Frankfurt on June 19, 2014.

Australia Imposes Targeted Ukraine-Related Sanctions on 50 Individuals and 11 Entities, published by the White Collar Defense and Investigations practice group on June 19, 2014.

The French Blocking Statute:  Effective Protection Against Cross-Border Discovery?, published by the Commercial Litigation and Class and Derivative Actions practice groups on June 19, 2014.

Canada Charges 3 Foreign Nationals with Bribery of Foreign Officials, published by the Global Anti-Corruptions/Foreign Corrupt Practices Act Team on June 6, 2014.

EU Makes It Easier for Creditors to Recover Cross-Border Debts in the EU in Civil and Commercial Matters, but Has the UK Missed a Trick?, published by the London Commercial Litigation practice group on June 5, 2014.

EU and Competition Law Update — June 2014, published by the European Antitrust and Competition practice groups on June 9, 2014.

Thailand:  Is a Coup d’etat Force Majeure?published by the Hong Kong Commercial Litigation group on June 6, 2014.

Clarification of the Approach to Non-Arbitrable Claims — Silica Investors v Tomolugen Holdings (Singapore High Court), published by the International Arbitration practice group on June 4, 2014.

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April 2014 Client Alerts

Practice groups throughout Bryan Cave often prepare alerts on issues of interest to our clients and friends. Listed below are the Client Alerts published in April 2014.  Please click on the title to read the full text of the Alert.

 U.S. Supreme Court Clarifies Test For Standing to Sue Under Federal False Advertising Statute And Rejects Test Used by Several Circuits to Prohibit Suits Brought By Non-Competitor Businessespublished by the Commercial Litigation, Intellectual Property and Trademarks practice groups on April 1, 2014.

The Australian Privacy Principles:  They don’t apply to me, do they?, published by the Data Privacy and Security team, April 1, 2014.

SEC Convenes Cybersecurity Roundtable:  Highlights Importance of Cybersecurity for Public Companies and Financial Market Participants, published by the Corporate Finance and Securities practice group and Data Privacy and Security Team, April 4, 2014.

Now It Gets Personal:  Department of Justice Obtains its First Ever Extradition on Antitrust Charges, published by the Antitrust and Competition White Collar Defense and Investigations practice on April 8, 2014.

SEC Touts Monetary Benefits of Whistleblowing, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement and Labor and Employment practice groups, April 10, 2014. 

Paving The Way for Increased Data Litigation, Court Refuses to Dismiss FTC’s Use of Deception or Unfairness Authority in Data Breach Cases, published by the Data Privacy and Security Team, April 11, 2014.

$5.15B Cleanup:  Anadarko Environmental Settlement Reveals New Government Tactics, published by the White collar Defense and Investigations and Environmental practice groups, April 11, 2014.

Court of Appeals Issues Opinion in Conflict Minerals Case:  Portion of Rule Violates First Amendment, published by the Corporate Finance and Securities practice group, April 14, 2014.

SEC Staff Responds to Court of Appeals Opinion in Conflict Minerals Case:  Game On, published by the Corporate Finance and Securities group, April 30, 2014.

Will This Be Enough?  Competitors Sharing Cyber Threat Information Will Not Result in Federal Antitrust Prosecutions — Sometimes, published by the National Security, Antitrust and Competition practice groups and the Data Privacy and Security Team

We Know Who You Are:  Companies’ Ability To Deal Confidentially With The CPSC is Further Eroded, published by the Consumer Protection and Data Privacy groups, April 18, 2014.

OCIE Issues Risk Alert Regarding Cybersecurity Preparednesspublished by the Broker-Dealer, Litigation, Arbitration and Regulatory,  and Investment Management groups, April 21, 2014.

Missouri Supreme Court Deals With Trade Secret Issues, published by the Labor and Employment practice group, April 22, 2014.

Missouri Supreme Court Introduces Drastic Change to Workers’ Compensation Retaliation Law, published by the Labor and Employment practice group, April 29, 2014.

New York’s Non-Profit Revitalization Act of 2013 and Its Impact on Non-Profit Organizations, published by the Non Profit Organizations practice on April 1, 2014.

U.S. Expands Sanctions Against Russia By Freezing More Assets and Restricting Exports (IRB No. 522), published by the International Trade group, April 29, 2014.

Partnership Tax Changes:  New Salaried Member Rules from 6 April 2014published by the Tax Advice and Controversy practice group (London) on April 3, 2014.

New Consumer Regulations – Implications for Retailers doing Business in the UK, published by the London Retail team, April 17, 2014.

Sunday Trading Laws in the UK — Is The Customer Still King?, published by the London Retail team, April 17, 2014.

UK Deferred Prosecution Agreements — Key Considerations For Companies Deciding Whether To Self-Report, published by the White Collar Defense and Investigations, Global Anti-Corruption/Foreign Corrupt Practices Act Team, April 2, 2014.

New Consumer Protection Law:  A Reinforced Framework for Distribution Agreements, published by the Paris Consumer Protection and Data Privacy group, April 9, 2014.

New Consumer Protection Law:  A Stricter Regime for Payment Terms, published by the Consumer Paris Protection and Data Privacy group, April 9, 2014.

EU & Competition Law Update – April 2014, published by the European Antitrust and Competition group, April 10, 2014.

 

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March 2014 Client Alerts

Practice groups throughout Bryan Cave often prepare alerts on issues of interest to our clients and friends. Listed below are the Client Alerts published in March 2014.  Please click on the title to read the full text of the Alert.

The Evisceration of Attorney-Client Privilege for In-House Investigations?  District Court Rules that Internal Investigations Conducted Pursuant to Regulatory Law and Corporate Policy are Not Protected by Attorney-Client Privilege or the Work-Product Doctrine, published by the White Collar Defense and Investigations, Securities Litigation and Enforcement, and Government Contracts Client Service Groups, March 17, 2014.

Supreme Court Holds Severance Payments Subject to FICA Taxation, published by the Tax Advice and Controversy practice group, March 26, 2014.

Will the Supreme Court Curtail Securities Fraud Lawsuits This Term? published by the Broker-Dealer Litigation, Arbitration and Regulatory Practice and Investment Management groups, March 26, 2014.

Managing Legal Risks:  Trends in Mobile, Text Message, Fax and Telephone TCPA Class Action Litigation, published by the Data Privacy and Security Team, March 5, 2014.

SOX Whistleblower Protections Extend to Employees of Contractors and Subcontractors of Public Companies, published by the Labor and Employment Client Service Group, March 6, 2014.

A Significant Change is Occurring Regarding Regulatory Oversight of Banks and Their Third Party Relationships.  Both Banks and their Vendors must pay attention, published by the Financial Services Client Service Group,  Prepaid and Emerging Payments Team, March 25, 2014.

US and EU Impose Economic Sanctions in Response to the Crisis in Ukraine (IRB No. 519), published by the International Trade group  CIS Team, March 7, 2014.

U.S. Supreme Court Limits Scope of SLUSA’s Preclusion of Securities Class Actions for Violations of State Law Where Fraudulent Scheme Did Not Directly Involve Plaintiffs’ Purchase or Sale of “Covered”  Securities, published by the Class and Derivative Actions and Securities Litigation and Enforcement practice groups, March 7, 2014.

San Francisco Passes “Ban the Box” Ordinance, published by the Retail practice group, March 20, 2014.  Employers will not longer be able to ask about applicants’ criminal records.

Tax News and Developments (Winter 2013-2014), published by the Tax Advice and Controversy Client Service Group, March 21, 2014.

Reminder:  File Protective Refund Claim by April 15, 2014 for Severance Payments Made During 2010, published by the Tax Advice and Controversy Client Service Group, March 19, 2014.

Continued Expansion of U.S., EU and Canadian Sanctions on Russian Entities and Individuals in Response to Events in Crimea, published by the International Trade group and CIS Team, March 24, 2014.

US and EU Impose Economic Sanctions in Response to the Crisis in Ukraine (IRB No. 519), published by the International Trade group  CIS Team, March 7, 2014.

Whistleblowing Procedures:  The French Data Protection Authority Widens the Scope of Authorized Data Processing, published by the Data Privacy and Security team (Paris), March 3, 2014.

Retention of Title Clauses – Seller Beware!, published by the Energy and Natural Resources practice group (Asia), March 25, 2014.  The English Court of Appeal decision in Caterpillar v John Holt & Company, and its analysis of “retention of title” and “no set-off” clauses, will be of interest to commodity traders, compliance officers and legal counsel in industries dealing with energy and natural resources internationally.

UK Labor and Employment Bulletin – March 2014, published by the London Labor and Employment practice group, March 20, 2014.

EU & Competition Law Update – March 2014, published by the Antitrust and Competition group, March 14, 2014.

LCIA Rules 2014 – Final Draft Released, published by the International Arbitration group, March 12, 2014.

 

 

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January 2014 – Bryan Cave Client Alerts

Client service groups throughout Bryan Cave LLP often prepare alerts on issues of interest to our clients and friends.  Listed below are the client alerts published in January, 2014.  Please click on the title to read the full text of the Alert.

Qualified Plan Limits, published by Employee Benefits and Executive Compensation, January 21, 2014

California “Do-Not-Track” Law Has Gone Into Effect, Requiring Some Websites to Revise Privacy Policy, published by the Data Privacy and Security Team, January 9, 2014

Federal Trade Commission Increases Interlocking Directorates Thresholds, published by Antitrust and Competition, January 24, 2014

Eleventh Circuit Holds that Affiliates of Indicted Contractor May Be Suspended from Government Contracting Indefinitely, Despite No Wrongdoing, published by Government Contracts, January 3, 2014

‘Single Asset Real Estate’:  A Concept in Need of Redefinition, published by Bankruptcy, Restructuring and Creditors’ Rights, January 15, 2014

Tax Court Upholds Captive Insurance Arrangement Despite Parent Guarantee and Captive’s Investment in Stock of Parent, published by Tax Advice and Controversy, January 16, 2014

Investment Funds Maintained by Charitable Organizations, published by the Fund Formation Team and Tax Exempt and Charitable Planning, January 7, 2014

Circuit Decision Requires Production of Foreign Bank Account Records, Thus Emphasizing Importance of IRS Amnesty Program, published by Tax Advice and Controversy and White Collar Defense and Investigations, January 9, 2014

SEC ALJ Imposes Six Month Bar on China Affiliates of Big Four Accounting Firms, published by White Collar Defense and Investigations and International Trade, January 24, 2014

Premerger Notification Thresholds Increased, published by Antitrust and Competition, January 24, 2014

EPA Adopts New ASTM Phase I Standard, published by the Environmental group, January 15, 2014

While Some Things Changed, Much Stays the Same as the EU and the United States Relax Sanctions Against Iran (IRB No. 517), published by International Trade, January 28, 2014

SCOTUS Limits the Exercise of General Personal Jurisdiction Over Multi-National Parent Corporations:  Daimler AG v. Bauman, published by Commercial Litigation, January 29, 2014

SEPA — Is There Some Respite for European and US Companies?, published by Financial Services, January 13, 2014

EU & Competition Law Update – January 2014, published by Antitrust and Competition, January 14, 2014

Overhaul of the BIS Unverified List Imposes New Requirements for Exporters (IRB No. 516), published by International Trade, January 21, 2014

UK Labor and Employment Law Bulletin – January 2014, published by Labor and Employment, January 23, 2014

Lokpal:  Finally a force to combat corruption in India, published by the India Practice Group, January 8, 2014

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February 2014 – Bryan Cave Client Alerts

Practice groups throughout Bryan Cave often prepare alerts on issues of interest to our clients and friends.  Listed below are the client alerts published in January 2014.  Please click on the title to read the full text of the Alert.

Voluntary for Now:  Federal Cybersecurity Framework Likely to Become the Base-Line Requirement for Critical Infrastructure Organizations and, Potentially, Many Other Businesses, published by the National Security Data Privacy and Security Team, February 20, 2014.

Managing Legal Risks:  Trends in Data Privacy & Security Class Action Litigation, published by the Data Privacy and Security Team, February 27, 2014.

Bankruptcy Court Limits Credit Bid Right In An Unnecessarily “Rushed” Sale Process, published by the Bankruptcy, Restructuring and Creditors’ Rights Practice, February 14, 2014.

Proposed Regulation Would Limit Ability to Restrict Public Disclosure of Product Information Submitted to the CPSC, published by the Consumer Protection and Data Privacy Practice, February 27, 2014.

FINRA Levies Record Fine for AML Violations, published by the Securities litigation and Enforcement and White Collar Defense and Investigations Practice Groups.

FINRA’s Sweep Letter Targets Cybersecurity, published by the Broker-dealer Litigation, Arbitration and Regulatory Practice, February 10, 2014.

Managing Legal Risks:  Trends in Advertising Class Action Litigation (2013 Year-In-Review), published by the Consumer Protection and Data Privacy and Class and Derivative Actions Practice Groups, February 18, 2014.

DINP Listed as Carcinogen Under Prop. 65, published by the Retail Team, February 28, 2014.

OCIE’s “Never-Before Examined Initiative,” published by the Broker-Dealer Litigation, Arbitration and Regulatory Practice.

Attorney-Client Privilege in FCPA Investigation Nullified Based on Crime-Fraud Exception, published by the White Collar Defense and Investigations, Internal Trade, Global Anti-Corruption/Foreign Corrupt Practices Act Team, February 25, 2014.

Yet Another List to Check:  the Foreign Sanctions Evaders (IRB No. 518), published by the International Trade Group, February 21, 2014.

A Year in the Garden, published by the London labor and Employment Practice, February 19, 2014.

EU & Competition Law Update – February 2014, published by the European Antitrust and Competition Practice, February 10, 2014.

PRC Labor Activity Issues Interim Provisions on Labor Dispatch, published by the Asian Labor and Employment International Practice, February 25, 2014.

The Introduction of Time Limits in Works Council Consultations:  An Attempt at Streamlining Employer-Employee Relations, published by the Paris Labor and Employment Practice, February 3, 2014.

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February 2012 Client Alerts

FINRA Issues Guidance on Protection of Customer Accounts

A recent alert from the Financial Industry Regulatory Authority (“FINRA”) is encouraging broker-dealers to reexamine their policies and procedures relating to protection of customer assets and accounts.  FINRA Regulatory Notice 12-05 advises broker-dealers that FINRA has received an increasing number of reports of customer funds being stolen as a result of instructions e-mailed to firms from customer e-mail accounts that have been compromised.  With that notice, FINRA also issued an Investor Alert advising the public about the reported incidents.  To learn more about the Notice and Alert, please click here to read the Alert published by the White Collar Defense & Investigations and Securities Litigation & Enforcement Client Service Groups and Data Privacy & Security Team on February 6, 2012.

Reporting Cybersecurity Risks — New Obligations for Publicly Traded Companies 

Most companies are aware that they may be required to report data security breaches to consumers and, in some instances, state attorneys general, the FTC, or HHS.  Publicly traded companies should bear in mind that they have to notify another group — their investors.  The SEC last year offered  first-of-its kind guidance on when companies should report cybersecurity incidents in their disclosure statements.  To learn more about the new requirements, please click here to read the Alert published by the Data Privacy & Security Team on February 14, 2012.

DOL Issues Final Fee Disclosure Rule

Earlier this year, the Department of Labor issued a final rule on the disclosure requirements for a contract or arrangement for services to a covered plan to be deemed “reasonable” under Section 408(b)(2) of the Employee Retirement Income Security Act of 1973 (“ERISA”).  These disclosure requirements become effective July 1, 2012 and apply to service contracts and arrangements entered into both before and after that date.  To learn more about the disclosures required and what plans or contracts may be excluded from the rule, please  Click here to read the Alert published by the Employee Benefits and Executive Compensation Client Service Group on February 7, 2012. 

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December 2011 Client Alerts

SEC and FINRA Issue Guidance on Broker Dealer Branch Inspections

Broker-Dealers who face inspections from regulators should take heed of recent guidance provided by the two principal securities regulatory agencies.  The regulators are the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations.  Their jointly issued “National Examination Risk Alert” offers guidance on policies and procedures that broker-dealers should consider for branch office inspection programs.  To learn more, please click here to read the Alert published by the White Collar Defense & Investigations and Securities Litigation & Enforcement Client Service Groups on December 13, 2011.

State Taxation of Former Residents’ Retirement Income

Recently, the New York State Department of Taxation and Finance issued an Advisory Opinion regarding whether New York State may impose income tax on distributions from a nonqualified deferred compensation plan made to a former resident.  The opinion, consistent with federal law, concluded that New York State may not impose tax on these retirement payments.  To read more about the Advisory Opinion, please click here for the Alert published by the Employee Benefits and Executive Compensation Client Service Group on December 28, 2011.

Reminder Regarding Information Reporting For Corporate Actions That Affect Stock Basis

Issuers of securities who undertook an “organizational action” in 2011 that affected the basis of such securities are required to file an information return reporting such action.  The Information Return for actions taken in 2011 was due to be filed January 17, 2012 for actions taken in 2011.  For more information on timing of returns for actions in 2012 and subsequent years, please click here to read the Tax Advice and Controversy Client Service Group Bulletin published December 30, 2011. 

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