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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…
Caplin & Drysdale, Chartered | USA | 6 Apr 2023
Tax Court Rules that IRS Lacks Statutory Authority to Assess Penalties for Failure to File Form 5471
On April 3, 2023, the Tax Court issued a blow to the IRS’s ability to collect certain international information return penalties. In the case Farhy v…
Caplin & Drysdale, Chartered | USA | 29 Dec 2022
IRS Takes Aim at Law Firms’ Deferred Payment Arrangements for Contingency Cases
When a U.S.-based cash-basis law firm receives a contingency fee, the fee generally is subject to U.S. federal income taxation in the year the…
Caplin & Drysdale, Chartered | USA | 7 Dec 2022
IRS to Issue Proposed Regulations Identifying Syndicated Conservation Easements as Listed Transactions
On December 6, 2022, less than a month after its historic loss in the Tax Court in Green Valley Investors LLC v. Commissioner, 159 T.C. 5 (2022), the…
Caplin & Drysdale, Chartered | USA | 25 Aug 2022
IRS Grants Penalty Relief for Certain 2019 and 2020 Returns
The IRS on August 24 released Notice 2022-36, Penalty Relief for Certain Taxpayers Filing Returns for Taxable Years 2019 and 2020 (the “Notice”). The…
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…
