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Sutherland: The 2012 Tax Litigation Year in Review: Important Events

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The 2012 Tax Litigation Year in Review: Important Events

Sutherland
January 15, 2013
4 pages

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]