Carbon capture, utilization, and sequestration projects around the United States received a significant boost from the Inflation Reduction Act of 2022. The IRA, which President Biden recently signed into law, includes approximately $369 billion in incentives for clean energy and climate-related program spending, including CCUS projects.
Client Alert | August 16, 2022
On August 7, 2022, the Senate voted 51-50 to pass the Inflation Reduction Act of 2022, which broadly addresses climate change, taxes, health care, and inflation. The action sends the measure to the House of Representatives for a vote as early as Friday of this week.
Client Alert | August 10, 2022
On July 27, 2022, Senator Joe Manchin (D-West Virginia) and Senator Majority Leader Chuck Schumer (D-New York) announced an agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 to address climate change, taxes, health care, and inflation.
Client Alert | July 29, 2022
London partner Sandy Bhogal and associates Bridget English and William Inchbald are the authors of the "United Kingdom" chapter in GLI - Corporate Tax 2022, published by Global Legal Group in July 2022.
Article | July 27, 2022
Expert Guides has named four Gibson Dunn partners to its 2022 edition of the Tax Expert Guide, which recognizes the top legal practitioners in the industry.
Firm News | July 8, 2022
Congress continues to debate enactment of the Build Back Better Act, which is expected to include major changes to the federal tax law. Meanwhile, other recently enacted tax legislation, including the sweeping tax reform enacted in 2017, continues to generate significant regulatory activity at the Treasury Department and IRS.
Publications | January 11, 2022
In this client alert, we provide a summary of the key policy drivers behind the introduction of a federal Corporate Tax on business profits in the United Arab Emirates, the key features of the proposed regime, and high level commentary contextualising the potential effects of the legislative reforms on our clients.
Client Alert | May 12, 2022
In this client alert, we outline a number of significant UK and international tax developments of recent weeks and months, many of which will continue to take shape as we move forward into 2022.
Client Alert | February 1, 2022
Washington, D.C. partners Saul Mezei and Terrell Ussing are the authors of "How Justices May Interpret Statutory Time Bar In Tax Context," published by Law360 Tax Authority on January 21, 2022.
Article | January 24, 2022
Gibson Dunn has been recognized in 20 categories in the 2022 edition of The Legal 500 Asia Pacific.
Firm News | January 13, 2022
Once more, 2021 demonstrated that constant change should become your friend and ally. After a second year of global uncertainty caused by the formidable challenges of the COVID-pandemic, we all long for a return “back-to-normal.” However, chances are that 2022 will continue to present drastic and unpredictable challenges.
Client Alert | January 13, 2022
Gibson Dunn earned 9 firm rankings and 18 individual rankings in the inaugural edition of the Chambers Greater China Region guide.
Firm News | January 12, 2022
Los Angeles partner Michael Desmond is the co-author of "The Potential for Tax Enforcement Through Subregulatory Guidance," published by Tax Notes Federal on November 15, 2021.
Article | December 13, 2021
Gibson, Dunn & Crutcher LLP is pleased to announce that Sanford Stark, Saul Mezei, and C. Terrell Ussing have joined the firm as partners in the Washington, D.C. office.
Press Releases | November 15, 2021
Ten Gibson Dunn partners were recognized in the Who's Who Legal 2021 Corporate Tax and Who's Who Legal 2021 Private Funds guides.
Firm News | November 5, 2021
Gibson, Dunn & Crutcher LLP is pleased to announce that the firm has elected 27 new partners, effective January 1, 2022.
Press Releases | November 4, 2021
If enacted into law in its current form, the Build Back Better Act would substantially extend and expand available clean energy tax incentives, including the investment tax credit (“ITC”), the production tax credit (“PTC”), and the carbon capture and sequestration credit. Gibson Dunn lawyers examine the current state of the proposed legislation.
Client Alert | October 13, 2021
Gibson Dunn earned 16 practice area rankings in the 2022 edition of The Legal 500 UK. Six partners were named to Legal 500’s Hall of Fame, recognizing individuals who receive consistent feedback from the market for continued excellence, and seven partners were named Leading Lawyers in their respective practices.
Firm News | October 7, 2021
Six Gibson Dunn partners were featured by Who’s Who Legal in its Thought Leaders – Global Elite 2021 guide. The publication features individuals who obtained the highest number of nominations from peers, corporate counsel and other market sources.
Firm News | September 28, 2021
Law360 named six Gibson Dunn partners among its 2021 MVPs. The Law360 MVP Awards feature lawyers who have “distinguished themselves from their peers by securing hard-earned successes in high-stakes litigation, complex global matters and record-breaking deals.” The list was published on August 30, 2021.
Firm News | September 8, 2021
Gibson, Dunn & Crutcher LLP is pleased to announce that Matt Donnelly has joined the firm’s Washington, D.C. office as a partner. Donnelly, formerly a partner with Baker Botts L.L.P., will continue his tax practice at Gibson Dunn.
Press Releases | September 1, 2021
On August 5, 2021, U.S. Senate Finance Committee Chairman Ron Wyden (D-Oregon) and U.S. Senate Finance Committee member Sheldon Whitehouse (D-Rhode Island) introduced legislation entitled the “Ending the Carried Interest Loophole Act.” According to a summary released by the Finance Committee, the legislation is intended to close “the entire carried interest loophole.” While this legislation is very similar to a previous proposal introduced by Chairman Wyden, this legislation appears to have a greater likelihood of passage given the Democratic party’s control of both chambers of Congress and the election of President Biden.
Client Alert | August 10, 2021
London partner Sandy Bhogal and associate Bridget English are the authors of "United Kingdom," [PDF] published in Global Legal Insights - Corporate Tax 2021, Ninth Edition in August 2021.
Article | August 4, 2021
Zum BMF-Schreiben vom 24.03.2021: Das Bundesministerium der Finanzen (BMF) hat vor kurzem zur körperschaftsteuerlichen Anerkennung von Gewinnabführungsverträgen Stellung genommen. Dies gibt Anlass, insbesondere sog. Altverträge, die vor dem 27.02.2013 abgeschlossen oder letztmals geändert worden sind, zu prüfen und ggf. anzupassen.
Client Alert | June 28, 2021
On May 28, 2021, the Administration released its fiscal year (FY) 2022 Budget, outlining a plan for $6 trillion of federal spending and $4.1 trillion in revenue for FY 2022 alone.
Client Alert | May 29, 2021
Gibson Dunn lawyers review the latest international and UK-based tax developments for spring 2021.
Client Alert | May 24, 2021
London partner Benjamin Fryer and associate Bridget English are the authors of the "United Kingdom" [PDF] chapter in Taxation of Crypto Assets published by Wolters Kluwer on November 13, 2020.
Article | May 13, 2021
Dallas associate Michael Cannon is the author of “The Clean Energy Revolution: Renewable Energy Tax Incentives and Issues” [PDF] published by Tax Notes Federal on April 12, 2021.
Article | April 12, 2021
Gibson, Dunn & Crutcher LLP is pleased to announce that Michael J. Desmond has joined the firm as a partner in the Los Angeles and Washington, D.C. offices.
Press Releases | May 3, 2021
New York associate Alex Marcellesi is the author of "Evaluating Creditor Continuity of Interest: A 10-Step Process," [PDF] published by Tax Notes Federal on March 15, 2021.
Publications | April 13, 2021
On April 6, 2021, New York Governor Andrew Cuomo signed into law Senate Bill 297B/Assembly Bill 164B, the long anticipated New York State legislation addressing the cessation of U.S. Dollar LIBOR.
Client Alert | April 8, 2021
On March 5, 2021, regulators and industry groups provided market participants with much anticipated clarity by announcing the dates for the cessation of publication of, and non-representativeness of, various settings of the London Interbank Offered Rate which will allow market participants to identify the date that their financial instruments and commercial agreements that reference LIBOR will transition to an alternative reference rate (e.g., a risk free rate).
Client Alert | March 9, 2021
At Gibson Dunn, we are proud and honored to be at your side to help solve your most complex legal questions and to continue our partnership with you in the coming year in Germany, in Europe and the world. We trust you will find this German Law Year-End Update insightful and instructive for the best possible start in 2021.
Client Alert | January 14, 2021
Four Gibson Dunn partners were featured in Who’s Who Legal Arbitration 2021 guide: London partners Cyrus Benson, Penny Madden and Jeffrey Sullivan were recognized and New York partner Rahim Moloo was named as a Future Leader.
Firm News | January 14, 2021
In a surprise u-turn, on 31 December 2020, the UK government took steps to narrow the scope of mandatory reporting under DAC 6.
Client Alert | January 4, 2021
New York associate James Manzione is the author of "Real Estate Partnerships: The Basics and Some Technical Stuff," [PDF] published by Tax Notes Federal on November 23, 2020.
Publications | December 23, 2020
Gibson Dunn lawyers review the latest international and UK-based tax developments for fall 2020.
Client Alert | December 22, 2020
Gibson Dunn earned 13 practice area rankings in the 2021 edition of The Legal 500 UK. Four partners were named to Legal 500’s Hall of Fame, recognizing individuals who receive consistent feedback from their clients for continued excellence, and four other partners were named Leading Lawyers in their respective practices.
Firm News | October 5, 2020
World Tax, in association with the International Tax Review, has recognized Gibson Dunn in two categories in its 2021 edition. The firm was recognized in the UK General Corporate Tax and Transactional Tax categories.
Firm News | September 29, 2020
On September 24, 2020, the UK Government announced its “Winter Economy Plan” – a series of employment and business support and tax measures intended to support the UK economy as the COVID-19 pandemic continues to impact economic output.
Client Alert | September 24, 2020
World Tax, in association with the International Tax Review, has named London partner Sandy Bhogal and Hong Kong partner Elaine Chen among its 2021 Tax Leaders.
Firm News | September 24, 2020
International Tax Review has named Murphy Oil's $2.127 billion divestment of its entire Malaysian operations to PTT Exploration and Production Company Limited (PTTEP), the publicly listed subsidiary of Thailand's national oil company, PTT, as one of its Impact Deals of the Year at the ITR Asia Tax Awards 2020.
Firm News | August 31, 2020
London partner Sandy Bhogal and associate Barbara Onuonga are the authors of "United Kingdom," [PDF] published in Global Legal Insights - Corporate Tax 2020, Eighth Edition in August 2020.
Publications | August 4, 2020
Gibson, Dunn & Crutcher LLP is pleased to announce that Pamela Lawrence Endreny has joined the firm’s New York office. Endreny, formerly a partner at Skadden, Arps, Slate, Meagher & Flom LLP, will continue to focus on advising clients in a broad range of U.S.
Press Releases | August 4, 2020
Legal Media Group’s Expert Guides has named London partners Jeff Trinklein and Sandy Bhogal to its 2020 edition of the Tax Expert Guide, which recognizes the top legal practitioners in the industry.
Firm News | July 17, 2020
Gibson Dunn lawyers in London outline various UK and international tax developments considered to be of greatest significance during the second quarter of 2020.
Client Alert | July 16, 2020
Best Lawyers in Germany 2021 has recognized 19 Gibson Dunn attorneys as leading lawyers in their respective practice areas. Frankfurt attorneys recognized include: Alexander Klein – Banking and Finance Law; Jens-Olrik Murach – Competition/Antitrust Law, and Litigation; Dirk Oberbracht – Corporate Law, Mergers and Acquisitions Law, and Private Equity Law; Wilhelm Reinhardt – Corporate Law, and Mergers and Acquisitions Law; Sebastian Schoon – Banking and Finance Law; and Finn Zeidler – Arbitration and Mediation, Criminal Defense, and Litigation.
Firm News | June 26, 2020
Best Lawyers in France 2021 recognized 17 Gibson Dunn attorneys and named Gibson Dunn the Insolvency and Reorganization Law “Law Firm of the Year.”
Firm News | June 25, 2020
Dallas associate Michael Cannon is the author of "Bankruptcy-Proximate Owner Shift? Loss Corporation Beware," [PDF] published by Tax Notes Federal on May 18, 2020.
Publications | June 15, 2020
Houston partner James Chenoweth, New York partner Brian Kniesly, and Los Angeles partner Lorna Wilson are the authors of “Covid-19, the CARES Act and Tax Planning for Real Estate and Passthrough Businesses--Part II,” [PDF] published by Bloomberg Tax on May 20, 2020.
Publications | May 22, 2020
Washington, D.C. associate Virginia Blanton, Dallas associate Michael Cannon and New York associate Jennifer Fitzgerald are the authors of "Double Tax Benefits in the CARES Act," [PDF] published by Tax Notes Federal on April 20, 2020.
Publications | May 18, 2020
It is expected that, from the end of 2021, London Interbank Offered Rates (“LIBORs”), which are used as reference rates in the loan, bond and derivatives markets, will cease to be published.
Client Alert | May 4, 2020
On Thursday, April 30, 2020, the Internal Revenue Service (the “IRS”) issued Notice 2020-32 (the “Notice”).[1] The Notice clarifies that, in the IRS’s view, expenses funded using the proceeds of Small Business Administration (“SBA”) loans extended pursuant to the Paycheck Protection Program are not deductible if the loan is forgiven.
Client Alert | May 1, 2020
The Legal 500 EMEA 2020 has recommended Gibson Dunn in 19 categories in Belgium, France, Germany and UAE.
Firm News | April 30, 2020
Houston partner James Chenoweth, New York partner Brian Kniesly, and Los Angeles partner Lorna Wilson are the authors of "Covid-19, the CARES Act and Tax Planning for Real Estate and Passthrough Businesses," [PDF] published by Bloomberg Tax on April 15, 2020.
Publications | April 20, 2020
Gibson Dunn lawyers detail some of the factors that have influenced the introduction of Digital Services Tax in the UK and its wider implications for multinational enterprises.
Client Alert | April 9, 2020
Asian-mena Counsel recognized Murphy Oil’s $2.127 billion divestment of its entire Malaysian operations to PTT Exploration and Production Company Limited (PTTEP), the publicly listed subsidiary of Thailand’s national oil company, PTT, with an honorable mention in its Deals of the Year for 2019.
Firm News | April 3, 2020
Gibson Dunn lawyers provide an update on various key tax-related announcements and developments in the United Kingdom during Q1 2020.
Client Alert | April 3, 2020
On Friday, March 27, 2020, Congress passed and President Donald Trump signed into law the third major piece of legislation intended to address the economic impact of the coronavirus (COVID-19) outbreak.
Client Alert | March 27, 2020
Internal Revenue Service (“IRS”) Notice 2020-18, issued March 20, 2020, provides updated guidance on the extension of the April 15, 2020 U.S. federal income tax return filing and payment deadlines for individuals and corporations to July 15, 2020 as a result of the Coronavirus pandemic.
Client Alert | March 27, 2020
Gibson Dunn lawyers discuss the ability for employers to provide tax-free financial assistance to employees who are affected, directly or indirectly, by COVID-19, while preserving the employer’s ability to deduct the payments of financial assistance, as a result of the President's declaration of a national emergency.
Client Alert | March 25, 2020
In the 2020 edition of Chambers Global, Gibson Dunn earned 155 total rankings – 56 firm practice group rankings and 99 individual rankings. The firm and its lawyers were recognized globally and in the Asia-Pacific, Europe, Latin America and Middle East regions, with additional recognitions in Belgium, China, France, Germany, India, Indonesia, the Philippines, Singapore, the United Arab Emirates, the United Kingdom and the United States.
Firm News | March 5, 2020
Los Angeles associate David Rubin is the winner of the International Fiscal Association’s 2019 International Tax Student Writing Competition for his paper “EB or Not EB?
Firm News | March 3, 2020
In January of 2020, the Maryland House and Senate introduced identical bills that would apply an additional 17% state income tax to (i) carried interest and management fee income attributable to certain investment management services provided in the state of Maryland and (ii) carried interest and management fee income earned by residents of Maryland, regardless of where the investment management services giving rise to the income are performed.
Client Alert | February 26, 2020
New York associate Alex Marcellesi is the author of "Guaranteed Payments and Interest: Why Treasury Is Overreaching," [PDF] published by Tax Notes Federal on December 9, 2019.
Publications | February 6, 2020
Who’s Who Legal named 15 Gibson Dunn partners to guides in their respective fields. Dubai partner Chézard Ameer, Hong Kong partner John Fadely, Los Angeles partner Jennifer Bellah Maguire, New York partners Shukie Grossman and Edward Sopher and Washington, D.C. partner C.
Firm News | January 30, 2020
London partner Benjamin Fryer and associate Barbara Onuonga are the authors of “The year in review,” [PDF] published in Financial Instruments Tax & Accounting Review in December 2019/January 2020.
Publications | January 27, 2020
Gibson Dunn lawyers discuss whether the United Kingdom’s withdrawal from the European Union means that U.K. shareholders will no longer be considered “equivalent beneficiaries” for purposes of the derivative benefits test in the limitation on benefits provision in U.S. tax treaties.
Client Alert | January 17, 2020
Gibson Dunn lawyers in Frankfurt and Munich provide a recap of developments in German law across numerous areas during 2019.
Client Alert | January 10, 2020
London partner Sandy Bhogal and associate Barbara Onuonga are the authors of “Taxing the Digital Economy,” [PDF] published in Corporate Tax 2020, 16th Edition by International Comparative Legal Guides in December 2019.
Publications | December 18, 2019
Gibson, Dunn & Crutcher LLP is pleased to announce that the firm has elected 13 new partners, effective January 1, 2020. “We congratulate our new partners on this important and well-deserved professional achievement,” said Ken Doran, Chairman and Managing Partner of Gibson Dunn.
Press Releases | November 20, 2019
On November 6, 2019, the IRS released its cost-of-living adjustments applicable to tax-qualified retirement plans for 2020. Gibson Dunn lawyers provide an overview of the updates.
Client Alert | November 6, 2019
On October 9, 2019, the U.S. Department of the Treasury published proposed regulations on the transition from interbank offered rates (IBORs) to other reference rates.
Client Alert | October 15, 2019
On October 9, 2019, the Internal Revenue Service released Rev. Rul. 2019-24, addressing two scenarios involving the taxation of virtual currencies.
Client Alert | October 10, 2019
Gibson, Dunn & Crutcher LLP is pleased to announce that Ben Fryer will join the firm as a partner in the London office. Currently a partner with Mayer Brown, Fryer will continue his tax practice at Gibson Dunn.
Press Releases | October 7, 2019
The UK Legal 500 2020 ranked Gibson Dunn in 15 practice areas and named seven partners as Leading Lawyers. The firm was recognized in the following categories:
Firm News | October 4, 2019
On September 23, 2019, the UK’s highest court ruled that Prime Minister Boris Johnson’s decision to suspend (or “prorogue”) Parliament for five weeks, from September 9, 2019 until October 14, 2019, was unlawful.
Client Alert | September 24, 2019
The Best Lawyers in America® 2020 has recognized 158 Gibson Dunn attorneys in 54 practice areas. Additionally, 48 lawyers were recognized in Best Lawyers International in Belgium, Brazil, France, Germany, Singapore, United Arab Emirates and United Kingdom.
Firm News | August 15, 2019
An update on the political state of play in the United Kingdom after Boris Johnson was selected as Prime Minister, covering Brexit and other developments.
Client Alert | July 26, 2019
Recent tax measures adopted, or contemplated, by States which target foreign investors may violate investment treaty obligations, including national treatment, and fair and equitable treatment obligations. These investment treaties give foreign investors the right to pursue claims directly against the State for such breaches.
Client Alert | July 24, 2019
Dallas associate Michael Cannon is the author of "Tell Me It’s Over: Tax Year Endings and M&A Transactions" [PDF] published by Tax Notes Federal on June 10, 2019.
Publications | June 10, 2019
Best Lawyers in France 2020 has recognized 16 Gibson Dunn attorneys as leading lawyers in their respective practice areas: Ahmed Baladi – Information Technology Law, Intellectual Property Law, Privacy and Data Security Law and Telecommunications Law; Nicolas Baverez – Administrative Law, Public Law and Regulatory Practice; Maïwenn Béas – Public Law; Amanda Bevan-de Bernède – Banking and Finance Law and Investment; Eric Bouffard – International Arbitration; Bertrand Delaunay – Mergers and Acquisitions Law and Private Equity Law; Jérôme Delaurière – Tax Law; Jean-Pierre Farges – Arbitration and Mediation, Banking and Finance Law, Insolvency and Reorganization Law and Litigation; Pierre-Emmanuel Fender - Insolvency and Reorganization Law; Benoît Fleury – Corporate Law
Firm News | July 1, 2019
London partner Sandy Bhogal is the author of “Can the U.K. Digital Services Tax Address the Digital Economy?” [PDF] published by Tax Notes International and Tax Analysts on June 24, 2019.
Publications | June 24, 2019
Gibson Dunn looks at what is driving tax considerations of the digital economy debate and provide an overview of certain digital tax proposals impacting the United Kingdom and the European Union.
Client Alert | June 20, 2019
Four Gibson Dunn partners were recognized by Who’s Who Legal in their respective fields. In Who’s Who Legal Thought Leaders – Tax 2019, two partners were recognized: London partner Sandy Bhogal and New York partner Eric Sloan.
Firm News | June 18, 2019
The political instabilities caused by Brexit raise the possibility that a General Election may be held in the UK sooner than the scheduled 5 May 2022. Given current political turbulence, the prospect of Labour winning any such snap election can no longer be dismissed. If this happens, a future Labour government led by Jeremy Corbyn and John McDonnell is expected to consider nationalising a range of assets.
Client Alert | May 9, 2019
On April 17, 2019, the Internal Revenue Service and the Treasury Department released proposed regulations that provide additional guidance regarding investing in “qualified opportunity funds” and “opportunity zones.”
Client Alert | April 22, 2019
The Legal 500 EMEA 2019 has recommended Gibson Dunn in 14 categories in Belgium, France, Germany and UAE. The firm was recognized in Competition – EU and Global in Belgium; Administrative and Public Law, Dispute Resolution – Commercial Litigation Industry Focus – IT, Telecoms and the Internet, Insolvency, Insurance, Mergers and Acquisitions, and Tax in France; Antitrust, Compliance, Internal Investigations and Private Equity in Germany; and Corporate and M&A and Investment Funds in UAE.
Firm News | April 19, 2019
On March 4, 2019, the U.S. Supreme Court held 7-2 that payments for lost wages due to on-the-job injuries are a form of taxable “compensation” under the Railroad Retirement Tax Act (RRTA).
Client Alert | March 4, 2019
New York associate Brian Hamano is the author of “Staking Out New Territory: Taxation of Proof-of-Stake Protocols” [PDF] published by Tax Notes on the January 28, 2019.
Publications | January 28, 2019
Looking back at the past year's cacophony of voices in a world trying to negotiate a new balance of powers, it appeared that Germany was disturbingly silent, on both the global and European stage.
Client Alert | January 11, 2019
This is an interesting time to be a UK citizen, not least because of the unpredictable political situation. However, UK tax policy regarding real estate investment and taxation of real estate structures has been a moving target since before the Brexit referendum.
Client Alert | December 17, 2018
London partner Sandy Bhogal and associate Panayiota Burquier are the authors of "Taxing the Digital Economy" [PDF] published in The International Comparative Legal Guide to: Corporate Tax 2019 on November 16, 2018.
Publications | November 16, 2018
London partner Sandy Bhogal is the author of “The Impact on MNCs” [PDF] published in Tax Journal on November 2, 2018.
Article | November 2, 2018
Gibson Dunn was recognized with two firm and 14 individual rankings in the 2019 edition of Chambers UK.
Firm News | November 2, 2018
U.S. News – Best Lawyers® awarded Gibson Dunn Tier 1 rankings in 132 practice area categories in its 2019 “Best Law Firms” [PDF] survey. Overall, the firm earned 169 rankings in nine metropolitan areas and nationally.
Firm News | November 1, 2018
In the current strong market environment, spin-off deals have become a regular feature of the M&A landscape as strategic companies look for ways to maximize the value of various assets. In this program, a panel of lawyers from a number of these key practice areas provided insights based on their recent experience structuring and executing spin-off transactions. They walked through the hot topics, common issues and potential work-arounds.
Webcasts | October 30, 2018
On October 19, 2018, the Internal Revenue Service (the "IRS") and the Treasury Department issued proposed regulations (the "Proposed Regulations") providing rules regarding the establishment and operation of "qualified opportunity funds" and their investment in "opportunity zones."
Client Alert | October 22, 2018
Our discussions with politicians, civil servants, journalists and other commentators lead us to believe that the most likely outcome of the Brexit negotiations is that a deal will be agreed at the “softer” end of the spectrum, that the Conservative Government will survive and that Theresa May will remain as Prime Minister at least until a Brexit deal is agreed (although perhaps not thereafter).
Client Alert | October 10, 2018
Dallas associate Michael Cannon is the author of "The 100 Percent Tax-Exempt Use Property Trap: Funds Beware" [PDF] published in Tax Notes on September 3, 2018.
Article | September 3, 2018