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Brendan J. Sponheimer

Mayer Brown LLP

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New IRS Transfer Pricing Directives

USA - January 18 2018 On January 12, 2018, the IRS Large Business and International ("LB&I") Division released a set of "Directives" regarding new transfer pricing...

John T. Hildy, Larry R. Langdon, Brian W. Kittle.


A Sisyphean Task: The House of Representatives Passes Tax Reform Legislation

USA - November 20 2017 Legend has it that Sisyphus was condemned to an eternity of pushing a boulder uphill, and then being crushed by it as it fell back down, all in...

Lewis J. Greenwald, Warren S. Payne, Jason S. Bazar, William G. McGarrity, Oren P. Margulies, Xiao Xiao, George W. Craven, Brian W. Kittle, James C.Williams, Mark H. Leeds, Edward C. Osterberg Jr., Lucas Giardelli.


The 2017 Proposed Federal Tax Legislation: A First Look.

USA - November 3 2017 After months of uncertain progress, tax reform has dramatically accelerated in the past few weeks. On November 2, U.S. House of Representatives Ways...

Lewis J. Greenwald, Warren S. Payne, Jason S. Bazar, William G. McGarrity, Oren P. Margulies, Brian W. Kittle, Edward C. Osterberg Jr., Lucas Giardelli.


Attorney-Client Privilege Claim Upheld in IRS Examination of Captive Insurance Company

USA - March 31 2017 On March 27, 2017, in U.S. v. Micro Cap KY Ins. Co. Inc., the federal district court upheld a claim of attorney-client privilege in a federal income...

Thomas L. Kittle-Kamp, Brian W. Kittle, Mark H. Leeds.


Sharpened knives: US Internal Revenue Service continues slicing through barrier options with CCA 201547004

USA - November 23 2015 The efforts of the US Internal Revenue Service (the "IRS") to broadly challenge the purported federal income tax consequences of barrier and basket...

Shawn R. O'Brien, Brian W. Kittle, Mark H. Leeds.