Dwight Mersereau

Dwight Mersereau

McDermott Will & Emery

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Focus on Tax Controversy - Summer 2014

In This Issue: - Waiver of Privilege: Disturbing Trends - New Repair Regulations Affect All Taxpayers - Unclaimed Property – It Is Not a Tax, but It Can Feel Like One - Excerpt from Waiver of...more

6/24/2014 - Attorney-Client Privilege Income Taxes IRS Privilege Waivers Repairs Unclaimed Property

Second Circuit Disagrees with Claims Court and Denies Deduction for Contingent Dividend Liability

On August 1, 2013, the U.S. Court of Appeals for the Second Circuit held in New York Life Ins. Co. v. U.S., that the taxpayer’s liability for policyholder dividends was contingent, and therefore, was not deductible until the...more

8/12/2013 - Deductions Dividends Insureds Liability Life Insurance

IRS Capitalized Legal Fees Incurred by Pharmaceutical Company

In a recently released Field Attorney Advice, the Internal Revenue Service (IRS) Office of Chief Counsel concluded that a pharmaceutical company must capitalize legal fees incurred to obtain Food and Drug Administration...more

4/15/2013

IRS Addresses Whether Publisher Is “Producer” Under §199

In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more

4/5/2013 - e-Books IRS Manufacturers Publishers Section 199 Tax Deductions

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