Elizabeth Erickson

Elizabeth Erickson

McDermott Will & Emery

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Focus on Tax Strategies & Developments - June 2015

In This Issue: - Distinguishing Between Captive Insurance and Related Party Derivatives: Chief Counsel Advice Memorandum 201511021 - Achieving Tax-Free ‘Rollover’ Treatment for Certain Shareholders in Acquisition of...more

6/23/2015 - Captive Insurance Company Corporate Restructuring Foreign Currency IRS Transfer Taxes

The New Section 6501(c)(10) Regulations

The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently finalized Treas. Reg. § 301.6501(c)-1(g), which interprets § 6501(c)(10)’s extended limitations period (and other associated rules) where a...more

4/24/2015

Focus on Tax Controversy - Spring 2015

In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more

4/16/2015 - Accounts Receivable Appeals Audits Captive Insurance Company Controlled Foreign Corporations Corporate Taxes Foreign Subsidiaries Insurance Litigation Royalties Tax Court Transfer Pricing

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

2/3/2015 - FBAR Foreign Financial Accounts IRS Offshore Funds OVDP Voluntary Disclosure

IRS Rules Captive Reinsurance Arrangement Involving Retiree Medical Benefits Qualifies as Insurance for Federal Tax Purposes

On May 18, 2014, the Internal Revenue Service (IRS) ruled that an employer’s wholly owned captive insurance subsidiary could reinsure the employer’s retiree medical benefit risks and still qualify as insurance for federal tax...more

6/2/2014 - Captive Insurance Company Healthcare IRS Medical Benefits Reinsurance Retirement

Inside M&A - Winter 2014

Delaware Court of Chancery Upholds Forum Selection Bylaws - In recent years, virtually every merger and acquisition (M&A) transaction of significant size involving a U.S. public company has been challenged in court. ...more

2/20/2014 - Board of Directors Corporate Taxes Shareholder Litigation Shareholders

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

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