Our inaugural issue focuses on a truly transnational and important rule of law: the attorney-client privilege and related protections against disclosure. While this is a topic common to all areas of law, the tax arena at...more
5/7/2021
/ Attorney-Client Privilege ,
Audits ,
Cost-Sharing ,
Disclosure ,
Dual Purpose ,
Financial Reporting Council (FRC) ,
IRS ,
Litigation Privilege ,
Microsoft ,
Stocks ,
UK ,
US v Microsoft ,
Valuation
Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute. The decision is also a victory for taxpayers generally because of the Ninth Circuit’s...more
On August 7, 2018, the Ninth Circuit panel vacated its earlier opinion in Altera v. Commissioner that, in a nutshell, had concluded that Treasury had complied with the Administrative Procedure Act (the “APA”) in issuing final...more
Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more