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Recent Court of Appeals Decision Provides Hope for Taxpayers Fighting for Congressionally Sanctioned Tax Benefits

USA - February 23 2017 For the second time in just over a year, the U.S. Court of Appeals for the Sixth Circuit reversed the United States Tax Court and affirmed the right...

Armando Gomez, Nathan P. Wacker, Alan J.J. Swirski, Raj Madan, Christopher P. Bowers.


Challenging the IRS anti-inversion notice: a hollow threat

USA - January 28 2015 On September 22, 2014, Treasury and the IRS issued Notice 2014-52, 2014-42 I.R.B. 712 (the Notice), announcing their intention to issue regulations...

Moshe Spinowitz, Kate A. Long, Christopher P. Bowers.