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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