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Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton’s APAs

USA - August 30 2017 On July 26, 2017, the Tax Court ruled that the IRS abused its discretion when it retroactively cancelled two Advance Pricing Agreements (APAs) with...

Patricia Gimbel Lewis, Elizabeth J. Stevens.

Different Viewpoint Not a Misrepresentation: Tax Court Holds IRS Abused Its Discretion in Cancelling Eaton’s APAs

USA - August 24 2017 On July 26, 2017, the Tax Court ruled that the IRS abused its discretion when it retroactively cancelled two Advance Pricing Agreements (APAs) with...

Patricia Gimbel Lewis, Elizabeth J. Stevens.

IRS Launches 13 Issue-Based Corporate Compliance Campaigns

USA - February 3 2017 On January 31, 2017, the Internal Revenue Service (IRS) launched its first wave of compliance "campaigns." A campaign is an issue-based compliance...

Zhanna A. Ziering, Kirsten Burmester, Niles A. Elber, Charles M. Ruchelman, Dustin J. Barzell, Neal M. Kochman, Mark D. Allison, Rachel L. Partain, James E. Salles.

Treasury Issues Final Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership

USA - December 19 2016 On December 12th, the IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by...

Kirsten Burmester, Arianna Caldwell, Scott D. Michel.

Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership

USA - April 5 2016 In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require...

Kirsten Burmester, Michael G. Pfeifer, Scott D. Michel, H. David Rosenbloom.