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Internal Revenue Service › Arbitrary and Capricious

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Morrison & Foerster LLP

Taxpayers Achieve Administrative Procedure Act Victories

Morrison & Foerster LLP on

Two recent federal district court decisions evaluated whether the process historically utilized by the Department of Treasury and the Internal Revenue Service (“IRS”) to issue guidance satisfied the requirements of the...more

Alston & Bird

Altera Redux – The Ninth Circuit Once Again Holds in Favor of the IRS

Alston & Bird on

The Ninth Circuit has repeated itself in reversing a unanimous Tax Court holding on the validity of the Treasury’s regulations under Section 482. Our International Tax Group examines the reconstituted panel’s significant...more

Carlton Fields

Cost-Sharing Regulations Revived By Ninth Circuit

Carlton Fields on

The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - October 2016

Proskauer Rose LLP on

Editor's Overview - This month, we look at the implications of the two federal district court cases from California that applied the ban on discretionary clauses typically found in ERISA plans to self-insured plans. The...more

McDermott Will & Emery

Arm’s Length Royalty Rates Save Medtronic from $1.36 Billion Tax Deficiency

McDermott Will & Emery on

Addressing whether certain intercompany technology license agreements were negotiated at arm’s length, the US Tax Court rejected the Internal Revenue Service’s (IRS’s) alleged $1.36 billion tax deficiency and determined that...more

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