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Shearman & Sterling: Focus on Tax Controversy and Litigation

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Focus on Tax Controversy and Litigation

Shearman & Sterling
November 9, 2012
10 pages

In this Issue:

Tax Court Cannot Reopen Whistleblower Claim in Cohen
Tax Court Includes Non-Sales Income in Gross Receipts for HP’s Section 41 Research Credit
Federal Court Confirms Solyndra Bankruptcy Plan
FATCA Update
Isle of Man Seeks Agreement to Prevent Tax Evasion by U.S. Taxpayers
IRS May Reassess Use of Step Transaction Doctrine to Stock-for-Debt Exchanges in Leveraged Spinoffs
New York Court Upholds Sales Tax on Adult Dance Performance

Latest Tax Litigation/Enforcement News

Dentons: Major Deadline Approaching to Minimize Exposure for Unclaimed Property Liability

May 14, 2013 Delaware’s Unclaimed Property Voluntary Disclosure Program

Shearman & Sterling: Focus on Tax Controversy and Litigation

May 02, 2013 Corporate Tax: Litigation & Enforcement

Winston & Strawn: Unclaimed Property Holders Beware: Delaware Unclaimed Property Voluntary Disclosure Program Is Being Followed by Aggressive Audit Enforcement

May 01, 2013 Delaware’s Unclaimed Property Voluntary Disclosure Program

Mayo Foundation & Standard of Review for Tax Regulations

Greenberg Traurig: The 'Mayo' Decision's Problematic Tax Analysis

Baker Donelson: Medical Residents and Other Working Graduate Students may be Subject to Social Security Taxes [Mayo Foundation]

Latham & Watkins: Mayo Foundation — The Supreme Court Clarifies The Standard Of Review For Tax Regulations

Quality Stores: FICA Tax on Severance Payments?

Goodwin Procter: FICA Tax Refunds May Be Available on Some Severance Pay

Baker Hostetler: Sixth Circuit Denies Government Motion for Rehearing in Quality Stores Employment Tax Challenge

Proskauer: Sixth Circuit Will Not Rehear Quality Stores Decision that Severance Pay in Connection with a Reduction in Force is not Subject to FICA; Supreme Court Next Step?

IRS Targets Total Return Swaps

Bingham: Withholding Approval: IRS Auditors Advised to Take Aim at Total Return Swaps on U.S. Equities

Sidley Austin: IRS Releases Audit Guidelines on Equity Swaps

Shearman & Sterling: IRS Industry Directive on Total Return Swaps Used to Avoid Dividend Withholding Tax

IRS Loses Veritas Cost-sharing Litigation

Cooley: IRS to Cost Sharing Agreement Participants: We Have Not Yet Begun to Fight … About the Valuation of Buy-In Payments

Morgan Lewis: IRS Disagrees with Veritas But Won't Appeal

DLA Piper: Taxpayers achieve major transfer pricing victory in determining cost sharing buy-in payments [Veritas v. Commissioner]

Vodafone v. Union of India: Foreign Buyer of Indirect Interest not Liable for Indian Tax

Latham & Watkins: Foreign Investors Threatened by Indian Measures Seek Remedies Through International Investment Arbitration

Freshfields Bruckhaus Deringer: Investing in high-growth jurisdictions: Vodafone and India budget 2012

Allen & Overy: India Considers Imposing Retrospective Tax

Xilinx & Cost Sharing of Employee Stock Options

Sullivan & Cromwell: IRS Acquiesces in Xilinx Decision but only for Pre-2003 Cases

Cooley Godward Kronish: Ninth Circuit Upholds Arm's-Length Standard, Rejects Cost-Sharing of Stock-Based Compensation [Xilinx]

Sullivan & Cromwell: Ninth Circuit Reverses Itself and Holds that the Arm’s-Length Standard Controls in Determining if Employee Stock Option Expenses Must Be Shared Among Related Parties Under Pre-2003 US Transfer Pricing Rules [Xilinx Inc v Comm'r]