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In re Majestic Star Casino, LLC, F.3d 736 (3rd Cir. 2013), the U.S. Court of Appeals for the Third Circuit broke from other courts by holding that S corporation status (or "qualified subchapter S subsidiary" or "QSub" status)...more
The U.S. Court of Appeals for the D.C. Circuit recently reversed two U.S. Tax Court decisions and held that an overstatement of basis constitutes an omission from gross income that is subject to the six-year statute of...more
Switzerland and the US Wednesday 31 March both signed an “amending protocol” to their 19 August 2009 agreement whereby the Swiss promised to issue final decisions on some 4,450 UBS bank clients whose account information was...more
On May 27, in a 2-1 panel decision, the Ninth Circuit Court of Appeals reversed the United States Tax Court in Xilinx, Inc. v. Commissioner and remanded on two specific issues. The Ninth Circuit held that, under Treasury...more
August 2009 agreement whereby Switzerland promised to issue final decisions on some 4,450 UBS bank clients whose account information was requested by US tax authorities. An Amended Protocol was signed on March 31, 2010....more
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