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New IRS guidance on tax treatment of attorney’s fees
  • Proskauer Rose LLP
  • USA
  • September 13 2013

The IRS recently released a memorandum advising taxpayers on the proper tax characterization of attorney's fee payments in connection with a

Does privilege apply to advice from non-legal professions?
  • Mayer Brown LLP
  • United Kingdom
  • April 22 2013

In a recent English Judgment concerning R (Prudential Plc and another) v. Special Commissioner of Income Tax and another 2013 UKSC 1, the Supreme

IRS says same-sex marriages are marriages for tax purposes no matter the state of residence
  • Haynes and Boone LLP
  • USA
  • September 6 2013

Recently, the IRS and Treasury Department announced that same-sex couples would be treated as married for all federal income tax purposes if the

Supreme Court holds valuation misstatement penalty applies to partners of a partnership disregarded due to lack of economic substance
  • Steptoe & Johnson LLP
  • USA
  • December 3 2013

The Supreme Court held today, in United States v. Woods, that the valuation-misstatement penalty can apply to partners in a case in which a

Federal tax law changes and opportunities for same-sex married couples
  • Choate Hall & Stewart LLP
  • USA
  • November 21 2013

As the result of the Supreme Court's recent decision in United States v. Windsor and a subsequent ruling by the IRS, same-sex couples who are

Implications of the Supreme Court’s Windsor decision on estate planning for same-sex couples
  • Patterson Belknap Webb & Tyler LLP
  • USA
  • July 29 2013

On June 26, 2013, the Supreme Court, in its decision in United States v. Windsor, overturned Section 3 of the Federal Defense of Marriage Act

UKSC declines to extend privilege to legal advice given by non-lawyers
  • Borden Ladner Gervais LLP
  • United Kingdom
  • March 19 2013

Not a surprising result, but a significant decision. PricewaterhouseCoopers (PwC) devised a tax avoidance scheme, which the Prudential group of

Be prudent with privilege: Legal advice from non-lawyers is not privileged under English and Bermuda Law
  • Sedgwick LLP
  • Bermuda, United Kingdom
  • January 23 2013

In its first major judgment of 2013, R (on the application of Prudential plc and another) v Special Commissioner of Income Tax and another 2013

Federal tax guidance for same-sex couples and employee benefit plans
  • Dykema Gossett PLLC
  • USA
  • September 6 2013

On August 29, 2013, the IRS and Department of Treasury issued the much anticipated, federal tax guidance adopting a rule that the marital status of a

IRS Guidance requires recognition of same-sex marriage for employee benefits
  • Caplin & Drysdale, Chartered
  • USA
  • September 4 2013

On August 29, 2013, the IRS issued Revenue Ruling 2013-17 which offers important guidance to employers on the application, for federal tax purposes