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SEPTEMBER  24, 2019
 
 
 
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In house attorneys looking for a better way to organize, vet and easily retrieve legal news created the National Law Review on-line edition.

Around the clock, the National Law Review's editors screen and classify breaking news and analysis authored by recognized legal professionals and our own journalists.

There is no log in to access the database and new articles are added hourly.
 
 
 
 
On September 10, 2019, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) on calculation of built-in gains and losses under Section 382(h) of the Internal Revenue Code of 1986, as amended.In general, the Proposed Regulations replace the existing guidance on the calculation of net unrealized built-in gains (“NUBIG”), net unrealized built-in losses (“NUBIL”), realized built-in gains (“RBIG”) and realized built-in losses (“RBIL”) under Section 382(h). More on Proposed Built-in Gains and Losses Regulations Here>
 
 
 
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In a prior post, I explained the basics of the Chicago Personal Property Lease Transaction Tax (“Transaction Tax”), including the applicability of the tax to tangible personal property and software, potentially applicable exemptions and exclusions from the tax, and collection issues. This follow-up post in the Practitioner Series further clarifies the application of the Transaction Tax to “cloud” software products and explores the interplay with the Illinois Retailers’ Occupation Tax (“ROT”).
Expanding the Definition of a Nonpossessory Computer LeaseAs explored in my prior post, the Transaction Tax is imposed upon leases or rentals in the City, including “nonpossessory computer leases”.
 More On Chicago's Cloud Software Lease Transaction Tax Here > 
 
 
 
Student loan borrowers commonly wonder whether they should refinance federal loans into private loans. There are many factors to consider in the case of federal loans, such as interest subsidies and possible forgiveness (but often with income tax consequences) paired with interest rates that are often lower in the case of private loans. Knowing the differences between federal and private student loans is imperative when making this decision.
Most notably, federal student loans are generally forgiven upon death whereas private lenders can, and generally  will pursue an estate for amounts owed by deceased borrowers. More On The Differences Between Federal and Private Student Loans Here>
 
 
 
When is the appropriate time to withhold FICA (social security and Medicare) tax on amounts deferred under a Nonqualified Deferred Compensation Plan ("NQDC Plan")? The following briefly summarizes the primary two withholding rules (the special timing rule and general timing rule) that apply to amounts credited to a NQDC Plan. More on FICA Taxes on Nonqualified Deferred Compensation Plans Here >
 
 
 
 
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