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Results: 1-10 of 11,942

Increase to available SBA leverage for single SBICs effective immediately for SBIC licensees

Winston & Strawn LLP
USA
August 15 2018

The U.S. Small Business Administration (“SBA”) has begun accepting applications from Small Business Investment Company (“SBIC”) licensees for

OECD BEPS Public Discussion Draft on Captive Insurance

Winston & Strawn LLP
OECD
August 14 2018

The OECD recently released a public discussion draft (“draft”) on Actions 8-10 of the Base Erosion Profit Shifting (“BEPS”) Action Plan. The draft

Ninth Circuit withdrew its opinion in Altera v. Commissioner

Winston & Strawn LLP
USA
August 14 2018

On July 24, 2018, the Ninth Circuit Court of Appeals, in Altera Corporation v. Commissioner, a case involving how expenses are allocated between

Ninth Circuit imposes transferee liability on shareholders in midco transaction

Winston & Strawn LLP
USA
August 14 2018

On July 24, the United States Court of Appeals for the Ninth Circuit in Slone v. Commissioner reversed a Tax Court decision which involved

IRS Announces the Selection of Five Compliance Campaigns

Winston & Strawn LLP
USA
August 14 2018

On July 2, 2018, the IRS Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. The five

Tax Court places burden of production in penalty challenges on partnerships

Winston & Strawn LLP
USA
August 14 2018

On May 7, 2018, the United States Tax Court issued a decision in Dynamo Holdings v. Commissioner,1 holding for the first time that in a

Supreme Court Rules No Physical Presence Required

Winston & Strawn LLP
USA
August 14 2018

On June 21, 2018, the Supreme Court of the United States, in South Dakota v. Wayfair, Inc., overturned decades of its own precedent in a 5-4 decision

Challenge to John Doe Summonses Fails on Sovereign Immunity Grounds

Winston & Strawn LLP
USA
August 14 2018

On July 5, 2018, the Sixth Circuit affirmed a decision by the Eastern District of Michigan, which had dismissed a challenge to the IRS’s use of John

Circuit Courts Reject Commissioner’s Substance Over Form Argument Regarding DISC-Roth Transactions

Winston & Strawn LLP
USA
August 14 2018

In April 2018, the First Circuit rejected the IRS’s attempt to recharacterize transactions between a domestic international sales corporation (DISC

IRS-CI Joins J5 to Fight Tax, Cryptocurrency, and Financial Crimes

Winston & Strawn LLP
USA, Australia, United Kingdom, OECD, Canada
August 14 2018

On July 2, 2018, the IRS launched a joint international effort to investigate cryptocurrency-related crimes and money laundering. In response to a

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