Lawrence Hill

Lawrence Hill

Shearman & Sterling LLP

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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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