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Results: 1-10 of 263

Tax Court overturns IRS cost-sharing regulation
  • Jones Day
  • USA
  • July 30 2015

On July 27, 2015, in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), the Tax Court held Treasury regulation section 1.482-7(d)(2) (the


U.S. Treasury Department releases proposed Model Treaty provisions
  • Jones Day
  • USA
  • June 1 2015

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying


Coupon discounts raise sales tax issues for retailers
  • Jones Day
  • USA
  • May 7 2015

Contingent fee lawyers across the country continue to throw their hats in the sales tax ring, filing lawsuits against retailers who honor discount


Illinois Attorney General's office announces intention to dismiss False Claims Act against liquor retailers
  • Jones Day
  • USA
  • April 30 2015

More than 50 cases have been filed against out-of-state liquor retailers and other retailers pursuant to the Illinois False Claims Act ("FCA") in


Employee stock plans: year-end international reporting requirements
  • Jones Day
  • USA
  • December 31 2014

This Commentary highlights some of the principal calendar and year-end reporting requirements for employee stock plans that U.S. companies most


Treasury Department and IRS issue long-awaited inversion guidance
  • Jones Day
  • USA
  • October 2 2014

On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets


IRS issues guidance regarding the deductibility of litigation fees incurred by branded pharmaceutical companies when defending their patents against challenges to market exclusivity by generic companies
  • Jones Day
  • USA
  • October 2 2014

There is welcome clarity for branded pharmaceutical companies seeking to deduct legal fees incurred in defending their patents against challenges to


OECD releases first BEPS recommendations to G20 in accordance with Action Plan
  • Jones Day
  • Global, USA
  • October 2 2014

As a part of the OECDG20 project to combat base erosion and profit shifting ("BEPS"), the OECD released the first set of reports and recommendations


Treasury Department and IRS issue long-awaited inversion guidance
  • Jones Day
  • USA
  • September 24 2014

On September 22, 2014, the U.S. Treasury Department and the IRS issued long-awaited inversion guidance in the form of Notice 2014-52. The Notice sets


FATCA recent developments
  • Jones Day
  • USA
  • June 3 2014

Implementation of the U.S. FATCA regime proceeds on schedule, with no changes to the effective dates, and none now expected. Thus, withholding will