Patrick J. McCurry
McDermott Will & Emery
Articles
Supreme Court holds six-year statute of limitations does not apply to overstatement of basis
USA - April 27 2012 On April 25, 2012, the Supreme Court of the United States affirmed the U.S. Court of Appeals for the Fourth Circuit’s decision in Home Concrete & Supply, LLC v. United States, 634 F.3d 249 (4th Cir. 2011), and held that an overstatement of basis does not constitute an omission from gross income that is subject to the six-year statute of limitations period under section 6501(e)(1)(A).
Final regulations on partnership debt-for-equity exchanges
USA - November 22 2011 The U.S. Department of the Treasury recently issued final regulations providing helpful clarifications on the partnership and partner level tax consequences of debt-for-equity exchanges.
Carried interest language narrowed, but remains far-reaching
USA - September 23 2011 This newsletter summarizes the Obama administration’s recent carried interest tax provision.
Another federal court of appeals weighs in on the applicability of the six-year statute of limitations period to an overstatement of basis
USA - August 4 2011 The U.S. Court of Appeals for the D.C. Circuit recently reversed two U.S. Tax Court decisions and held that an overstatement of basis constitutes an omission from gross income that is subject to the six-year statute of limitations period under sections 6229(c)(2) and 6501(e)(1)(A).
