Richard Nessler

Richard Nessler

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 & 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

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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