Andrew R. Roberson

Andrew R. Roberson

McDermott Will & Emery

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Ensuring Timely Filing with Private Delivery Services

Most of us are aware of the timely-mailed-timely-filed “mailbox rule” contained within the Internal Revenue Code. Most of us are probably also aware that a document mailed with a private delivery service may also qualify for...more

6/3/2014 - DHL Electronic Filing FedEx IRC IRS Mailbox Rule Tax Court UPS USPS

Tax Court Extends Implied Waiver of Privilege to Taxpayers’ State of Mind Penalty Defense

The U.S. Tax Court concludes in AD Investment 2000 Fund LLC v. Commissioner that a taxpayer’s assertion of a state of mind penalty defense waives the attorney-client privilege with respect to tax opinions provided to the...more

4/28/2014 - Attorney-Client Privilege Privilege Waivers Tax Court

IRS Revises Directive on IDR Issuance and Enforcement Process

On February 28, 2014, the Internal Revenue Service Large Business and International Division released updated guidance for examiners incorporating and superseding two directives relating to Information Document Requests. The...more

3/5/2014 - Business Taxes Corporate Taxes Enforcement IRS

Focus on Tax Controversy - December 2013

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more

12/5/2013 - Administrative Procedure Act False Claims Act Fraud IRS Mayo Foundation for Medical Ed Mayo Foundation v US Protective Claims SCOTUS Standard of Review State Taxes Tax Refunds Transfer Pricing Treble Damages U.S. Treasury US v Home Concrete & Supply Whistleblowers

The 3M Case: Can the IRS Overrule the Supreme Court?

3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more

9/27/2013 - 3M Company Income Taxes IRS SCOTUS Subsidiaries Tax Refunds

Courts Continue Literal Interpretation of Subpart F Rules on Income Inclusion

Consistent with prior judicial precedent, the U.S. Court of Appeals for the Fifth Circuit recently applied a literal interpretation of the Subpart F inclusion rules based on the plain meaning of Sections 951 and 956....more

7/18/2013 - Income Taxes Plain Meaning Statutory Interpretation Tax Reform

CCRC Fees – A Primer on the Tax Treatment of Entrance and Monthly Fees

I. Introduction - Continuing care retirement communities (CCRCs) are professionally managed retirement communities, many of which also function as long-term skilled nursing care facilities. CCRCs offer residents...more

12/5/2012 - Continuing Care Retirement Communities Nursing Homes Retirement

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