Lawrence Hill

Lawrence Hill

Shearman & Sterling LLP

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Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

9/25/2014 - Corporate Taxes International Tax Issues Inversion IRS Tax Evasion U.S. Treasury

First Circuit Rejects Talley and Allows a Business Expense Deduction for Settlement Payments Made Under the False Claims Act

On August 13, 2014, the United States Circuit Court for the First Circuit rejected the United States’ request to deny Fresenius Medical Care Holdings Inc. from deducting a portion of a settlement payment to settle civil...more

8/19/2014 - Compensatory Damages False Claims Act Fresenius Settlement Tax Refunds

Focus on Tax Controversy and Litigation - July 2014

In this issue: - Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing - Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more

7/17/2014 - Administrative Hearings Attorney-Client Privilege Enforcement IRS OECD OVDP SCOTUS Summons Work-Product Doctrine

Focus on Tax Controversy and Litigation - May 2014

In this issue: - Tax Court Rejects Partnerships’ Claim of Attorney-Client Privilege and Orders Release of Opinion Letters - Litigation Heats Up in Section 1603 Cash Grant Program for Renewable Energy Projects...more

5/29/2014 - Affirmative Defenses Attorney-Client Privilege Credit Suisse Deadlines Discovery FATCA Late Payments Rule 37 SCOTUS Tax Liability Wells Fargo

Focus on Tax Controversy and Litigation - Supreme Court Decides Woods v. Commissioner, Holds for IRS on Jurisdictional and...

In this issue: - US Supreme Court Imposes Valuation-Misstatement Penalty in TEFRA Proceeding - Southern District of New York holds Cooperation with Government Waives Attorney-Client Privilege - IRS Issues...more

4/11/2014 - Attorney-Client Privilege Banks DOJ Foreign Banks Income Taxes IRS Jurisdiction SCOTUS Settlement Tax Evasion TEFRA United States v Woods

District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case...

In this issue: - Swiss Bank Settlement Dilemma - District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit - Court of Federal Claims Holds for Government in BB&T STARS...more

11/6/2013 - Foreign Banks Income Taxes Offshore Banks OVDP SCOTUS Tax Evasion United States v Woods

Timeline for Initial FATCA Implementation Extended

The Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) announced on July 12, 2013 a general six-month extension to the timeline for initial implementation of the Foreign Account Tax Compliance Act...more

7/16/2013 - Delays FATCA FFI Foreign Banks IGAs IRS U.S. Treasury

Focus on Tax Controversy & Litigation - July 2013

In this issue: - District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo - IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition...more

7/10/2013 - Business Privilege Corporate Taxes Income Taxes IRS Private Letter Rulings Tax Accrual Workpapers Tax Shelters Wells Fargo Work Product Privilege

Focus on Tax Controversy and Litigation - June 2013

In this issue: - Supreme Court Holds in Favor of PPL in UK Windfall Profits Case - US District Court Rejects Talley and Permits a Business Expense Deduction for Part of Double Damages Payment Under the False...more

6/5/2013 - Damages EU False Claims Act IRS Offshore Funds Penalties SCOTUS Tax Evasion Windfall Tax

US District Court Rejects Talley and Permits a Business Expense Deduction for Part of Double Damages Payment Under the False...

In a taxpayer-favorable decision earlier this month, the US District Court for the District of Massachusetts, following a jury verdict, entered judgment for a corporation in a tax refund suit permitting a business deduction...more

5/21/2013 - Business Taxes Civil Monetary Penalty Compensatory Damages Corporate Taxes False Claims Act Punitive Damages Tax Deductions Tax Refunds

Focus on Tax Controversy and Litigation

In this issue: - Shearman & Sterling Secures Favorable Settlement of $807 Million IRS Claim Against Ambac Financial Group - AIG Case Requires Economic Substance for Transactions Generating Foreign Tax...more

4/30/2013 - AIG Amazon Ambac Financial Group COBRA Credit Default Swaps OVDP SCOTUS Tax Credits Transfer Pricing

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