Business Organization Tax Conflict of Laws

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Equityholder's Strategy for Shifting Tax Burdens to Creditors Upheld by Third Circuit

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

Another Federal Court of Appeals Weighs in on the Applicability of the Six-Year Statute of Limitations Period to an Overstatement...

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

United States v. UBS AG,

Amended Protocol Between the U.S. and Switzerland (Amending August 2009 Agreement)

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

Ninth Circuit Reverses Tax Court on Including Stock Option Costs in Cost-Sharing Agreement: A Tale of Two Regulations

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

United States v. UBS AG,

U.S. - Switzerland Protocol Amending Treaty for the Avoidance Double Taxation

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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