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Treasury Releases Final DebtEquity Regulations
  • Jones Day
  • USA
  • October 20 2016

On October 13, 2016, the U.S. Treasury Department released final debtequity regulations under section 385 of the Internal Revenue Code aimed


New Private Use Safe Harbors for Tax-Exempt Hospitals and Other Qualified Users: New Flexibility, New Restrictions, and Open Questions
  • Jones Day
  • USA
  • September 8 2016

New safe harbor guidelines released by the IRS on August 22, 2016 (Rev. Proc. 2016-44) are likely to have a significant impact on a variety of


Demystifying the Tax Provisions of the TPP
  • Jones Day
  • Global, USA
  • August 22 2016

International trade watchers have high hopes for the Trans-Pacific Partnership Agreement (“TPP”) and its potential impact on business taxes and, by


The Voluntary Payment Doctrine Defense Is Alive and Well in Illinois
  • Jones Day
  • USA
  • August 5 2016

The issue of tax overcollection has triggered a spate of consumer fraud lawsuits (often in the form of class actions) across the country, and it has


Food, Dietary Supplement & Cosmetics Regulatory Update, Vol. III, Issue 10
  • Jones Day
  • Cuba, European Union, USA
  • July 12 2016

On June 23, 2016, Senator Pat Roberts (R-Kansas) and Senator Debbie Stabenow (D-Michigan) reached an agreement to solve the state-by-state labeling


DOJ Issues Rule Implementing Bipartisan Budget Act and Doubling FCA Civil Penalties
  • Jones Day
  • USA
  • July 12 2016

On June 29, 2016, the Department of Justice ("DOJ") issued an interim rulethe Civil Monetary Penalties Inflation Adjustment, 81 Fed. Reg. 42,491


Tax Court Rejects IRS Transfer Pricing Approach in Medtronic
  • Jones Day
  • USA
  • June 20 2016

Medtronic Inc. & Consolidated Subsidiaries v. Commissioner (T.C. Memo. 2016-112) is the latest defeat for the U.S. Internal Revenue Service ("IRS"


Crutchfield v. TestaCan States Tax Online Interstate Retailers Based on Their Virtual Presence?
  • Jones Day
  • USA
  • May 31 2016

On May 3, 2016, the Supreme Court of Ohio heard oral argument between Crutchfield Corporationa major electronics retailer based in Virginiaand Ohio


Taxpayers and Retailers Be Warned!
  • Jones Day
  • USA
  • May 27 2016

The Tenth Circuit's Recent Decision in Brohl Presents the Supreme Court with an Opportunity to Reconsider Quill and the Physical Presence Requirement


IRS Extends Windpower Developers' Time to Receive Production Tax Credits
  • Jones Day
  • USA
  • May 27 2016

On May 5, 2016, the Internal Revenue Service ("IRS") updated guidance regarding the "beginning of construction" requirement for renewable energy