Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations -
Introduction:
On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more
10/5/2015
/ Administrative Procedure Act ,
Amended Regulation ,
BEPS ,
Clawbacks ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Cost-Sharing ,
Foreign Corporations ,
Goodwill ,
Intangible Property ,
IRC Section 367 ,
IRS ,
Partnerships ,
Proposed Regulation ,
Section 482 ,
Stock-Based Compensation ,
Tax Court ,
Tax Reform ,
Transfer Pricing ,
Transfers ,
U.S. Treasury
In This Issue:
A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more
12/5/2013
/ Administrative Procedure Act ,
False Claims Act (FCA) ,
Fraud ,
IRS ,
Mayo Foundation for Medical Ed ,
SCOTUS ,
Standard of Review ,
State Taxes ,
Tax Refunds ,
Transfer Pricing ,
Treble Damages ,
U.S. Treasury ,
Whistleblowers