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
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