myCorporateResource.com

Skip to content

You are here: Area of Law

Corporate Tax: Litigation & Enforcement

Shearman & Sterling: Focus on Tax Controversy and Litigation

Skip to content

Trending ..... Section 336(e) & Disposition of Subsidiary Stock ..... Marketplace Fairness Act ..... Tax Reform ..... FY 2014 Budget..... Final FATCA Regs ..... Fiscal Cliff (ATRA) ..... Historic Boardwalk Hall ..... Higher Medicare Taxes for Higher Earners ..... IRS Guidance on Personal Use of Corporate Aircraft ..... FATCA's Model Intergovernmental Agreements ..... Estate & Gift Tax Legislation ..... Penalty Framework For Offshore Accounts

Focus on Tax Controversy and Litigation

Shearman & Sterling
February 26, 2013
16 pages

In this Issue:

Tax Court Disregards STARS Transaction as Lacking Economic Substance
Tax Matters Partner Seeks Review of Third Circuit’s Historic Boardwalk Decision
Union Carbide Seeks Supreme Court Review of Research Expenses
District Court Enjoins IRS From Enforcing Registered Tax Return Preparer Regulations
Eleventh Circuit Joins Three Others in Upholding Application of the Required Records Exception to Foreign Financial Accounts
Seventh Circuit Dismisses UBS Account Holders’ Suit

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]