Jean Pawlow

Jean Pawlow

McDermott Will & Emery

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Latest Publications


Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

7/15/2015 - Corporate Taxes Dividends Double Taxation EU France Germany HMRC Income Taxes Italy Multinationals Mutual Agreement Procedure Required Documentation Subsidiaries Tax Avoidance Tax Credits Tax Penalties Tax Refunds Taxable Distributions TFEU Transfer Pricing UK

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

The IRS May Require Taxpayers to File Formal Refund Claims During an Audit

The Internal Revenue Service (IRS) has drafted new rules relating to the filing of informal refund claims during an examination. An informal refund claim is a request for a refund by the taxpayer either in a written form,...more

10/31/2014 - Audits IRS Tax Refunds

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

Focus on Tax Controversy - Spring 2014

Company Jet Audit Issues: A Word to the Wise - Once a business attains a certain level of success, an aircraft often becomes a valued asset. Public and closely held private companies alike find that the use of a...more

3/18/2014 - Aircraft Audits Corporate Taxes IRS

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

District Court Accords Work Product Protection to Taxpayer Documents Prepared during a Transaction’s Planning Stages

The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more

12/9/2013 - Bank Holding Company Corporate Taxes Discovery Federal Rules of Civil Procedure Income Taxes IRS Rule 26 Work Product Privilege

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 SCOTUS Standard of Review State Taxes Tax Refunds Transfer Pricing Treble Damages U.S. Treasury Whistleblowers

The Other Shoe Drops

On November 4, 2013, the Internal Revenue Service (IRS) Large Business and International Division released a much anticipated directive on its new Information Document Request enforcement process. Scheduled to take effect in...more

11/19/2013 - Document Requests Enforcement IRS

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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