200-state-street

Corresponding with Cornelius – a new series of blog posts

Not all of my online conversations take place here at Compliance Building. I try to make as many comments in other places as I do here. Twitter is a sporadic stream of thoughts, comments, and replies. I also try to leave as many comments on other blogs as I do posts here. I think you […]

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congressman sandy levin

Carried Interest Tax Legislation

We saw in the Obama budget (A New Era of Responsibility) that the administration was looking to raise revenue by taxing the carried interest for private investment funds. I was waiting to see how that one line item in the budget might translate into actual legislation and a change in tax policy. Congressman Sandy Levin […]

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Document Behaviors

A version of this post originally appeared in my old blog: KM Space. I have been focusing a lot of attention on the behaviors towards documents. After all, a wiki page is just another type of document. When producing documents, I have noted five types of behaviors: collaborative, accretive, iterative, competitive and adversarial. Collaborative With […]

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barclays

Breaking Down Compliance Silos: The Cost-Effective Approach to Managing Compliance

Michael Rasmussen, President of Corporate Integrity, Julian Parkin, Group Privacy Programme Director at Barclays, and John Kelly, Director at OpenPages, spoke in a webinar on taking a strategic approach to managing compliance. The webinar was sponsored by Compliance Week. These are my notes. Michael set the stage by asking: Does your organization walk its talk? […]

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skadden

Whistleblower Programs: Challenges for Multinational Companies

Katherine D. Ashley, Gary DiBianco, Dana H. Freyer, Matthias Horbach, Pierre Servan-Schreiber of Skadden, Arps, Slate, Meagher & Flom LLP put together a nice article addressing the challenges of exporting the whistleblower requirements under Section 301 of Sarbanes-Oxley to operations in the European Union: Whistleblower Programs: Challenges for Multinational Companies.  Section 301 of the Sarbanes-Oxley […]

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IRS Issues New Guidance on COBRA Subsidy

The Internal Revenue Service has issued Notice 2009-27 (.pdf), providing new guidance relating to the COBRA subsidy made available under the American Recovery and Reinvestment Act of 2009. Notice 2009-27 provides guidance on the definition of involuntary termination and assistance eligible individual. It also provides more detail on calculating the subsidy and determining the election […]

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RW Associates

Developing a Culture of Honesty and Integrity…its Not Easy!

EthicsPoint sponsored and presented a webinar from Bob Phillips of RW & Associates, Inc. on Developing a Culture of Honesty and Integrity…its Not Easy! These are my notes. Bob started with a quote from Stephen Covey: “The leader of the future, of the next millennium, will be one who creates a culture or value system […]

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nba

NBA and OFAC

It is unusual to see a story where the National Basketball Association intersect with the U.S. Treasury’s Office of Foreign Assets Control. But that is the lot in life for the 7-foot-2 Hamed Haddadi, a back up center for the Memphis Grizzlies. Since Mr. Haddadi is from Iran, he is apparently subject to the decades […]

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Ten Principles for a Black Swan-Proof World

Nassim Nicholas Taleb penned an opinion piece in the Financial Times: Ten principles for a Black Swan-proof world . Check out the piece for details behind each item: 1. What is fragile should break early while it is still small. 2. No socialisation of losses and privatisation of gains. 3. People who were driving a […]

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lexisnexis

Martindale-Hubbell’s Counsel to Counsel Forum

The folks over at Martindale-Hubbell were nice enough to invite me to their latest Counsel to Counsel Forum in Washington D.C. The forum operates under the rule that “what is said in the room stays in the room” so I will not share any details, but there were a few themes that I think I […]

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