Richard Nessler

Richard Nessler

Shearman & Sterling LLP

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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

4/21/2016 - C-Corporation IRS Sale of Assets Stock Sale Agreements

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

1/29/2016 - Audit Policies K-1 Partnerships Tax Planning TEFRA

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 & 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 (FCA) IRS Offshore Funds Penalties SCOTUS Tax Evasion Windfall Tax

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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