The IRS recently released an internal memorandum concluding that typical 'bad boy guaranties' provided by a partner for partnership debt should be treated as a recourse liability of the guarantor for purposes of allocating the debt, and associated deductions, among the partners. That result could reduce the amount of depreciation deductions that would be allocable to the non-guarantor partners. The memorandum was severely criticized in the tax community, as its conclusion was inconsistent with the way in which most practitioners...

The European Union Article 29 Working Party (Article 29) issued an opinion on the proposed EU-U.S. Privacy Shield framework agreement (Privacy Shield) earlier this week, stating that although the Privacy Shield was a “great step forward,” the Article 29 group identified several areas in which it found the Privacy Shield to be unacceptable, including that it permits the U.S. to carry out “massive and indiscriminate” bulk surveillance of European Union citizens. On the other hand, just a day later...

Manufacturing’s pivot East in recent decades has opened up new opportunities for DS-Concept across the globe, but more recently we have registered demand to open up an office in Los Angeles to allow domestic clients to expand overseas and for foreign businesses to operate with ease in the US. The manufacturing industry’s rapid growth in California has been one of the main drivers of the state’s growth, with $149.79bn in manufactured goods exported in 2014, more than 11% of the state’s...

RPL Managing Partner, Emmy Award®-Winning Executive Producer Celebrated as Social Justice Champion On April 12, 2016, the Women’s City Club of New York (WCC) announced Helen D. “Heidi” Reavis, Esq., Managing Partner and Principal at Reavis Parent Lehrer LLP, among the Honorees of the 2016 Civic Spirit Award.  In addition to her outstanding law practice in employment, media, intellectual property and other practice areas, Ms. Reavis  is an Emmy Award®-Winning Executive Producer who, with her husband, Steven...

According to April remittance data, the $40.0 million 100 Nassau Park Boulevard was recently sent to special servicing. Scheduled to mature in February 2017, the loan makes up 2.40% of the remaining collateral behind BSCMS 2007-PW15. The loan is backed by a 215, 143 square-foot, three-story office building in West Windsor, New Jersey. E.R. Squibb and Sons, LCC, a subsidiary of the biopharmaceutical firm Bristol-Myers Squibb, is the sole tenant with a lease that expires in December 2016. Bristol-Myers Squibb plans...

This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt Practices Act (FCPA). Under the new program, companies that self-disclose and satisfy the DOJ's expectations for cooperation and remediation can obtain up to a 50 percent reduction off the low end of the potential fine range that would otherwise be applicable to the violation. The program furthers the...

A modification of existing law resulting from the Trade Facilitation and Trade Enforcement Act recently signed into law on February 24, 2016 significantly expands duty saving opportunities in the direct internet sales sector as it increases the dollar limits of shipments that qualify for duty free importation. This increase should be of particular interest to the fashion and luxury goods sector because their duty rates are high and the increased exemption level may make the provision of law a more viable tool...

On March 3, 2016, DeVore & DeMarco joined a crucial, timely, and ongoing legal debate.  A debate about privacy and about security.  A debate about the power of the state and the power of a private corporation in the digital era.  On that date, on behalf of the Federal Law Enforcement Officers Association, the Association of Prosecuting Attorneys, and the National Sheriffs’ Association we filed an Amicus Curiae “Friend-of-the-Court” brief in U.S. District Court for the Central District of California...