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13 results found

Article

McDermott Will & Emery | USA | 4 Oct 2017

District Court Holds Anti-Inversion Regulation Unlawfully Issued

"We are not inclined to carve out an approach to administrative review good for tax law only." Mayo Found. for Medical Educ. & Research v. United

Article

McDermott Will & Emery | USA | 2 Oct 2017

Supreme Court Denies Review of QinetiQ

We have previously written about QinetiQ U.S. Holdings. Inc.’s (QinetiQ) fight to apply the Administrative Procedure Act (APA) to notices of

Article

McDermott Will & Emery | USA | 23 Aug 2017

Court Rejects Taxpayer’s Claim for US-Swiss Treaty Coverage

On August 14, 2017, the United States District Court for the District of Columbia (DC District Court) decided Starr International Company, Inc. v

Article

McDermott Will & Emery | USA | 13 Apr 2017

APA Challenge to Notice of Deficiency: QinetiQ Requests Supreme Court Review

On April 4, 2017, QinetiQ U.S. Holdings, Inc. petitioned the US Supreme Court to review the US Court of Appeals for the Fourth Circuit's decision

Article

McDermott Will & Emery | USA | 10 Jan 2017

APA Challenge to Notice of Deficiency: QinetiQ Affirmed

On January 6, 2017, the U.S. Court of Appeals for the Fourth Circuit, by published opinion, affirmed the U.S. Tax Court’s (Tax Court) earlier ruling

Article

McDermott Will & Emery | USA | 4 Jan 2017

Court Opinions - A Year In Review

Several notable court opinions were issued 2016 dealing with a variety of substantive and procedural matters. In our previous post - Tax Controversy

Article

McDermott Will & Emery | USA | 31 Oct 2016

APA Challenge to Notice of Deficiency: QinetiQ Oral Arguments

On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192

Article

McDermott Will & Emery | USA | 10 Aug 2016

Offshore Voluntary Disclosure Update

The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs in which to report foreign assets

Article

McDermott Will & Emery | USA | 3 Aug 2016

Law School Professors File Amicus Briefs in Support of Commissioner’s Position in Altera

Two groups of law school professors have filed amicus briefs with the US Court of Appeals for the Ninth Circuit in support of the government's

Article

McDermott Will & Emery | USA | 21 Apr 2016

Update on APA Challenges to Notice of Deficiency

In an earlier blog post, we discussed the US Tax Court’s ruling in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 14122-13 (Dec. 27, 2013). The

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