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Caplin & Drysdale, Chartered logo
For half a century, Caplin & Drysdale has been a leading provider of a full range of tax, tax controversy, and related legal services to companies…
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Caplin & Drysdale, Chartered | USA | 28 Jun 2022

Supreme Court overturns Roe v. Wade: What does it mean for nonprofits?

In On June 24, 2022, in Dobbs v. Jackson Women's Health Organization, 1 the Supreme Court ruled that there is no constitutional right to abortion…
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Caplin & Drysdale, Chartered | USA | 24 Jun 2022

Supreme Court Alert: Supreme Court Finds U.S. Trustee Fee Increase Unconstitutional

In a decision rendered on June 6, 2022, Justice Sotomayor authored the Supreme Court’s unanimous decision in the case Siegel v. Fitzgerald, holding…
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Caplin & Drysdale, Chartered | USA | 22 Mar 2022

Obtaining Refunds of Section 6707A and Section 6707 Penalties Paid for Not Properly Reporting Listed Transactions or Transactions of Interest (Including Notice 2007-83 and Notice 2016-66)

On March 3, 2022, in a unanimous opinion authored by its Chief Judge, the U.S. Court of Appeals for the Sixth Circuit invalidated an IRS listing…
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Caplin & Drysdale, Chartered | USA | 17 Mar 2022

Defined Contribution Plan Alert: IRS Proposes New Rules for Required Minimum Distributions

On February 24, 2022, the IRS issued proposed regulations (the “Proposed Regulations”) for determining the required minimum distribution (“RMD”)…
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Caplin & Drysdale, Chartered | USA | 21 Dec 2021

Taxpayer Defeats IRS Penalty in Tax Court for Conservation Easement Transaction

On November 20, 2021, the Tax Court ruled in favor of our client facing penalties related to disallowed charitable contribution deductions for…
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Caplin & Drysdale, Chartered | USA | 17 Dec 2021

Ready or Not, It’s Time for Transparency- FinCEN Proposes Rules to Implement Beneficial Ownership Reporting Requirements

Proposed regulations promulgated on December 8, 2021 by the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the…
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Caplin & Drysdale, Chartered | USA | 29 Oct 2021

Supreme Court Alert: Supreme Court Declines to Address the Viability of the Equitable Mootness Doctrine

On October 12, 2021, the U.S. Supreme Court denied, without comment, a petition for a writ of certiorari in a case challenging the doctrine of…
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Caplin & Drysdale, Chartered | Malta, USA | 17 Aug 2021

IRS “Dirty Dozen” List Includes “Potentially” Abusive Use of U.S.-Malta Tax Treaty in Pension Plans

The Internal Revenue Service (IRS) has placed certain Malta-based pension plan arrangements on its annual "Dirty Dozen" list of "tax scams." In its…
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Caplin & Drysdale, Chartered | USA | 22 Jul 2021

Reverse Claw-Backs Revisited: IRS Issues Post-Altera Guidance on Adjustments for Stock-Based Compensation Costs and Cost Sharing Arrangements

An IRS Office of Chief Counsel memorandum released July 16, 202 provides a roadmap for IRS transfer pricing Examinations involving cost sharing…
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Caplin & Drysdale, Chartered | USA | 8 Jun 2021

Leaving on a Jet Plane? Not without a Residency Audit.

Changes in the Administration, high state tax rates, and COVID-19 have all increased the spotlight on where taxpayers wish to call home. For some, a…
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