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Foreign fund’s lending and underwriting activities constituted U.S. trade or business

USA - January 16 2015 In Chief Counsel Advice 201501013, released early this month, the IRS concluded that a foreign fund was engaged in a U.S. trade or business based on…

Co-authors: James E. Croker, Jr., Henry J. Birnkrant , Sam K. Kaywood, Jr, Edward Tanenbaum, George Abney.


Economic substance doctrine confusion

USA - November 3 2014 On October 9, 2014, the IRS issued Notice 2014-58, attempting to provide some further clarification around the partially "codified" economic…

Co-authors: James E. Croker, Jr., Henry J. Birnkrant , Sam K. Kaywood, Jr, Edward Tanenbaum, George Abney.


House and Senate bills aim to tighten anti-inversion rules

USA - July 15 2014 Following the administration budget's proposal for stricter anti-inversion legislation, Congressmen Chris Van Hollen and Sander Levin have introduced…

Co-authors: James E. Croker, Jr., Henry J. Birnkrant , Sam K. Kaywood, Jr, Edward Tanenbaum, George Abney.


Supreme Court may consider economic substance doctrine

USA - May 1 2014 Several taxpayers have petitioned or are considering petitioning the Supreme Court of the United States to review their losses at the hands of lower…

Co-authors: James E. Croker, Jr., Henry J. Birnkrant , Sam K. Kaywood, Jr, Edward Tanenbaum, George Abney.


Federal tax crimes

USA - April 1 2014 Few taxpayers are aware of the operations of the Criminal Investigation Division of the IRS, and rightly so. Out of hundreds of millions of tax…

Co-authors: Sam K. Kaywood , Jr, Henry J. Birnkrant , James E. Croker , Jr, Edward Tanenbaum, George Abney.

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