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Focus on Tax Controversy and Litigation - The Unprecedented Extraterritorialization of Tax Crimes

In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States discussing a managing partner’s...more

Brexit: Key Issues for General Counsel

On June 23rd, the UK electorate voted to leave the European Union in an advisory referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with the...more

Brexit and Other Key Issues for CFOs and Corporate Treasurers

On June 23, 2016, the UK electorate voted to leave the European Union in an advisory Referendum. We expect the UK Government to commence negotiations to withdraw and to establish a framework for the UK’s new relationship with...more

Focus on Tax Controversy and Litigation - Treasury and IRS Issue Proposed Regulations Imposing Documentation Requirements Under...

In addition to the discussion of the recently proposed regulations which impose new documentation requirements under Section 385, this month’s issue features articles regarding the Circuit Court decision in Chemtech Royalty...more

MIDCO Transactions and the Expanding Universe of Transferee Liability

On April 20, 2016, partner Lawrence Hill (New York-Tax) presented a paper (co-authored with counsel Richard Nessler (New York-Tax)) titled “MIDCO Transactions and the Expanding Universe of Transferee Liability” to The Tax...more

Focus on Tax Controversy and Litigation - New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection...

In addition to the discussion of the new partnership audit rules, this month’s issue features articles regarding a recent district court decision in Ellis v. United States regarding the attorney-client privilege and work...more

New Partnership Audit Procedures May Dramatically Affect the Assessment and Collection of Taxes Relating to Partnership Activities

The Bipartisan Budget Act of 2015 (the “BBA”), which was signed into law in November 2015, includes sweeping changes to the rules governing federal tax audits of entities treated as partnerships for US federal income tax...more

Focus on Tax Controversy and Litigation - Second Circuit Determines that Tax Memo Shared Between Taxpayers and Banks Is Protected...

In addition to the discussion of the Second Circuit’s decision in Schaeffler, this month’s issue features articles regarding the “new” IRS Notices covering “Basket Options” and “Basket Contracts”, the Tax Court’s recent...more

Second Circuit Determines That Tax Memo Shared Between Taxpayers and Banks Is Protected Under the Common Interest Doctrine and...

On November 10, 2015, the US Court of Appeals for the Second Circuit unanimously held in a published opinion that (i) the attorney-client privilege was not waived by appellants-taxpayers who shared a group of documents,...more

Focus on Tax Controversy and Litigation - United States Tax Court Invalidated Treasury Regulation § 1.482-7(d)(2)

In addition to the discussion of the Tax Court’s decision in Altera, this month’s issue features articles regarding Notice 2015-47 “Basket Options” and Notice 2015-48 “Basket Contracts”, the Federal Circuit Court of Appeals...more

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

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

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

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

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

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

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

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

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

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

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