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"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

"Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits"

For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right of a taxpayer to structure its affairs in a manner that takes into account...more

"IRS Guidance Clarifies 'Begun Construction' Standard for Renewable Electricity Production Credit Property"

The Internal Revenue Service (IRS) has released welcome new guidance with respect to renewable electricity production and energy investment tax credits. A notice issued on May 5, 2016, reflects changes to the production tax...more

"Major Changes to Tax Audit Procedures to Impact Most Partnerships"

Legislation enacted in November 2015 will fundamentally change the way the Internal Revenue Service (IRS) examines entities treated as partnerships for U.S. federal tax purposes, including how it assesses and collects tax...more

"Congress Extends Renewable Energy Tax Credits"

On December 18, 2015, President Barack Obama signed into law the Consolidated Appropriations Act, 2016 (Act), which extends and modifies the investment tax credit for solar energy property, the production tax credit for wind...more

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

"IRS Guidance Clarifies Renewable Energy Tax Credit"

The Internal Revenue Service (IRS) has released welcome new guidance on renewable electricity production and energy investment tax credits. A notice issued on August 8, 2014, addresses when a facility or equipment maintains...more

"Supreme Court Clarifies Standard to Challenge IRS Summons"

On June 19, 2014, the U.S. Supreme Court in United States v. Clarke1 held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing an administrative summons when the taxpayer...more

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

"Supreme Court Rules on Partnership Tax Shelter Penalties"

In United States v. Woods,1 the U.S. Supreme Court ruled unanimously for the government on two long-brewing disagreements over penalty jurisdiction in the partnership context and over the breadth of valuation misstatement...more

"IRS Announces New IDR Enforcement Process"

On November 4, 2013, the Internal Revenue Service released an internal directive that completes a two-part process of reshaping the dynamic between taxpayers and IRS examiners during the information-gathering phase of an...more

White House Budget Proposes Numerous Tax Changes as Congressional Tax-Writing Committees Focus on Reform

On April 10, 2013, the White House released its proposed budget for fiscal year 2014. The budget contains significant tax proposals related to renewable energy, research and job creation, as well as numerous changes affecting...more

"IRS Guidance on the Commencement of Construction Requirements for Tax Credits for Qualified Energy Facilities"

On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more

"House Ways and Means Proposal Would Change the Tax Treatment of Partnerships and S Corporations"

The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more

3/29/2013

"Temporary ‘Fiscal Cliff’ Solution Yields Important Tax Changes"

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012 (the TRA of 2012), which permanently extends certain federal income tax rate reductions first enacted in 2001 that were scheduled to expire...more

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