Adam Halpern

Adam Halpern

Fenwick & West LLP

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Section 385 Proposed Regulations

On April 4, 2016, Treasury and the IRS proposed sweeping regulations under § 385 of the Code. Issued the same day as the anti-inversion temporary regulations, the proposed § 385 rules would go much farther than merely...more

5/2/2016 - Anti-Inversion Regulations Corporate Taxes Debt Debt Securities Equity Expanded Group Instruments (EGIs) IRS Stocks Tax Planning U.S. Treasury

Court Strikes Down IRS Tax Return Preparer Regulations

In Loving v. IRS, Civ. A. No. 12-385 (D.D.C. 2013), the District Court for the District of Columbia struck down the IRS's 2011 tax return preparer regulations (T.D. 9527, 2011-2 C.B. 1 (Jun. 3, 2011)). The regulations require...more

1/23/2013 - IRS Tax Preparers

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