William Bonano

William Bonano

Pillsbury Winthrop Shaw Pittman LLP

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Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

8/8/2015 - Administrative Procedure Act Chevron Deference Corporate Taxes Cost-Sharing Foreign Subsidiaries IRS Parent Corporation Section 482 Stock Options Stock-Based Compensation Tax Court Tax Deductions Treasury

Don’t Shoot the Messenger: The Expanding Scope of the John Doe Summons

The John Doe summons is an information-gathering tool that has been available to the IRS for many years, traditionally used to seek information about unknown persons suspected of tax evasion from banks, investment advisors or...more

4/30/2015 - DHL FedEx Financial Institutions Government Investigations IRS John Doe Investigation Summons Tax Evasion UPS

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

6/9/2014 - DOJ FBAR Foreign Bank Accounts Foreign Banks IRS OVDP Penalties

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