Dentons | USA | 17 Oct 2016
On October 13, 2016, the US Internal Revenue Service (IRS) released final and temporary regulations that recharacterize certain debt between related…
Dentons | USA | 16 Mar 2016
The proposed Department of Treasury regulations (REG-115452-14) under IRC section 707(a)(2)(A) set forth standards to determine when a payment…
Dentons | USA | 11 Jan 2016
In a unanimous decision in Gillette Co. v. Franchise Tax Board, the California Supreme Court on December 31 held that the Multistate Tax Compact is…
Dentons | USA | 18 Dec 2015
The Consolidated Appropriations Act of 2016, or as it is more commonly known, the "Omnibus," does more than just fund the federal government for the…
Dentons | USA | 2 Dec 2015
In a taxpayer win, the Ninth Circuit recently reversed the Tax Court and held equitable recoupment was not time barred. Revah v. Comm'r, No. 11-70211…
Dentons | USA | 29 Oct 2015
The proposed Department of Treasury Regulations under IRC Section 707(a)(2)(A) set forth standards to determine when a payment arrangement to a…
Dentons | USA | 9 Jan 2015
In Chief Counsel Advice 201501013 (CCA), issued on January 5, 2015, the Internal Revenue Service (IRS) considered whether a fund manager (US Manager)…
Dentons | USA | 17 Dec 2014
President Obama is expected to sign bill extending tax provisions that expired at end of 2013 It's been called "a terrible way to make tax policy"…
Dentons | USA | 29 Sep 2014
Notice 2014-52, released by the US Treasury Department on September 22, 2014, is intended to disrupt, and in some cases prevent, so-called corporate…
Dentons | European Union | 23 May 2014
In a recently reported Emerging Markets Series of DFA Investment Trust Company case (C -190/12) the European Court of Justice confirmed that…