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 Credits

- Amazon Fights Service Over Transfer Pricing Issues

- Supreme Court Directs Parties to Argue Section 6226 Jurisdictional Issue in COBRA Case Gary Woods

- Swiss Bank Wegelin Sentenced for Conspiring to Evade Taxes

- Supreme Court Hears Oral Arguments in PPL Corp. v. Commissioner

- Tax Court Erred in Holding Limitations Period Not Tolled

- Tax Court Hears Concurrent Expert Witness Testimony

- US and Switzerland Sign Intergovernmental Agreement to Implement FATCA

- IRS Disqualifying Certain Taxpayers After Acceptance into Voluntary Offshore Disclosure Program; GAO Reports that IRS May Be Missing Continued Evasion

- Former Tax Attorney Sentenced for Promoting Illegal Tax Shelters

- Excerpt from: Former Tax Attorney Sentenced for Promoting Illegal Tax Shelters

On March 1, 2013, the US Attorney for the Southern District of New York announced that Donna Guerin, a tax lawyer formerly with Jenkens & Gilchrist, was sentenced to eight years in prison following her guilty plea on conspiracy and tax evasion charges relating to her work designing, marketing, and implementing tax shelters.53 According to Guerin’s plea, she was involved in the design, marketing, and implementation of a variety of tax shelters including “Short Sales,” “Short Options Strategy” (“SOS”), “Swaps,” and “HOMER.” These shelters generated billions of dollars in false tax losses.

Please see full newsletter below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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