Roger J. Jones

Roger J. Jones

McDermott Will & Emery

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Latest Publications


Focus on Tax Strategies & Developments - October 2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

10/5/2015 - Administrative Procedure Act Amended Regulation BEPS Clawbacks Controlled Foreign Corporations Corporate Taxes Cost-Sharing Foreign Corporations Goodwill Intangible Property IRC Section 367 IRS Partnerships Proposed Regulation Section 482 Stock-Based Compensation Tax Court Tax Reform Transfer Pricing Transfers U.S. Treasury

Statute of Limitation: Congress Overrules Home Concrete and Retroactively Removes Some Taxpayer Defenses

On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law. In addition to extending various...more

8/20/2015 - Adjusted Gross Income Barack Obama Detrimental Reliance Highway Trust Fund IRS Overstatement of Basis Retroactive Taxes Statute of Limitations Surface Transportation and Veterans Health Care Choice Improvement Act Tax Returns

Altera: Tax Court Invalidates Section 482 Regulation on Administrative Law Grounds

In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm’s-length...more

8/20/2015 - Administrative Procedure Act Cost-Sharing Decision-Making Process Harmless Error IRS Notice and Comment Stock-Based Compensation Tax Court Treasury

The New Section 6501(c)(10) Regulations

The Internal Revenue Service (IRS) and the U.S. Department of the Treasury recently finalized Treas. Reg. § 301.6501(c)-1(g), which interprets § 6501(c)(10)’s extended limitations period (and other associated rules) where a...more


Court Weighs in on Deadline for Filing FTC Refund Claims

On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more

10/15/2014 - Court of Federal Claims Foreign Taxpayers IRC IRS Jurisdiction Statute of Limitations Tax Credits Tax Refunds

Ensuring Timely Filing with Private Delivery Services

Most of us are aware of the timely-mailed-timely-filed “mailbox rule” contained within the Internal Revenue Code. Most of us are probably also aware that a document mailed with a private delivery service may also qualify for...more

6/3/2014 - DHL Electronic Filing FedEx IRC IRS Mailbox Rule Tax Court UPS USPS

Focus on Tax Controversy - December 2013

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more

12/5/2013 - Administrative Procedure Act False Claims Act Fraud IRS Mayo Foundation for Medical Ed SCOTUS Standard of Review State Taxes Tax Refunds Transfer Pricing Treble Damages U.S. Treasury Whistleblowers

The 3M Case: Can the IRS Overrule the Supreme Court?

3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more

9/27/2013 - 3M Company Income Taxes IRS SCOTUS Subsidiaries Tax Refunds

CCRC Fees – A Primer on the Tax Treatment of Entrance and Monthly Fees

I. Introduction - Continuing care retirement communities (CCRCs) are professionally managed retirement communities, many of which also function as long-term skilled nursing care facilities. CCRCs offer residents...more

12/5/2012 - Continuing Care Retirement Communities Nursing Homes Retirement

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