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COVID-19: IRS Postpones Tax Deadline and Court and Agency Closures Will Delay Federal Tax Cases

Notice 2020-18 provides welcome economic relief from filing and payment obligations for certain federal income taxes; however, traps for the unwary exist. Tax Deadline – Key Points: ..On March 20, 2020, the Internal Revenue...more

Planning for Tax Controversies Before, During and After the Deal: New Dynamics in Cross-Border M&A Under the TCJA

Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...more

Tax Act Changes Deductibility of False Claims Act Payments

The new tax law limits the deductibility of False Claims Act settlements and requires that settlement agreements identify the deductible “restitution” amount. Settlements under the False Claims Act (FCA), which often...more

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