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You are here: Area of Law Tax Corporate Tax: Litigation & Enforcement Shearman & Sterling: Focus on Tax Controversy and Litigation

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ShearmanSterlingLogoFocus 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

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