Eva Farkas-DiNardo

Treasury's Investigation of U.S. Clients of Swiss Banks

In 2009, The U.S. Justice Department and the U.S. Treasury Department increasded their efforts to uncover U.S. taxpayers who were allegedly evading U.S. taxes by hiding their assets in Switzerland, a country that still maintains…more
| International Law & Trade, Taxation

Examining the Alcatel-Lucent and Daimler-Chrysler Mergers -The Merger of Equals

Relevant in its day, the article compares two mergers of equals - the Alcatel-Lucent and the Daimler-Chrysler mergers - and briefly analyzes the US tax consequences…more
| Taxation

Back-to-Back Computer Licensing Arrangement Not Subject to Sec. 901(l)

This article analyzes Notice 2005-90. In that Notice, the IRS addressed fears that IRC Section 901(l) would prevent taxpayers from claiming foreign tax credits for foreign withholding taxes incurred on income derived through…more
| Taxation

Authorities Learn From Market on Taxation of Credit Default Swaps

This article describes a growing international market for credit default swaps, and examines the IRS's request for information with respect to CDS terms and pricing, along with the market participants' response and detailed…more
| International Law & Trade, Taxation

IRS Issues New Partnership Withholding Rules

The article reviews and analyzes the partnership wihholding rules issued by the IRS in 2005, which changed many provision under the previous regime that tended to result in over-withholding…more
| Taxation
This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×