Focus on Tax Controversy and Litigation
Shearman & Sterling
December 20, 2012
23 pages
In this Issue:
- A Closer Look at Pre-Filing Agreements 14 Second Circuit Reverses Convictions of Two Tax Attorneys in Coplan
- Making Sense of the Tax Court’s Recent Debt-Equity Cases: Hewlett-Packard, ScottishPower, and PepsiCo
- Treasury Releases Model II FATCA Agreement, Announces Initialing of Intergovernmental Agreement with Switzerland
- Ninth Circuit Holds That Discovery of Wrongful Disclosure of Taxpayer Information Triggers the Running of the Statute of Limitations
- NYC Transfer Tax Not Applicable to Mitchell-Lama Conversion
- Second Circuit Reverses Convictions of Two Tax Attorneys in Coplan
- IRS Advice Concludes Economic Substance Doctrine May Apply to Securities Lending Transactions
- In Civil FBAR Penalty Case, Burden of Proof Standard is Preponderance of the Evidence
- IRS Updates Disclosure Rules for Accuracy-Related Penalty in Revenue Procedure 2012-51
- Foreign Tax Credit Generator Update and Chart
