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17 results found

Article

Sullivan & Cromwell LLP | USA | 7 Aug 2018

Ninth Circuit Withdraws Altera Opinion Reversing Tax Court on Cost-Sharing Arrangements: New Judge Added to Panel to Reconsider the Appeal

On August 7, 2018, the U.S. Court of Appeals for the Ninth Circuit withdrew its July 24, 2018 opinion in Altera Corporation v. Commissioner to allow

Article

Squire Patton Boggs | USA | 11 Dec 2017

OFAC Penalty - D.C. Circuit

On May 26, 2017, the D.C. Circuit upheld a fine imposed by the U.S. Department of the Treasury Office of Foreign Assets Control ("OFAC") for violation

Article

Winston & Strawn LLP | USA | 30 Oct 2017

District Court Invalidates Portion of Anti-Inversion Regulations

On September 29, 2017, a federal district court in Texas granted a motion for summary judgment and set aside as unlawful the government's

Article

Shearman & Sterling LLP | USA | 24 Oct 2017

Texas Federal District Court Invalidates IRS Regulations Limiting Inversion Transactions

On September 29, 2017, the United States District Court for the Western District of Texas granted summary judgment in favor of the U.S. Chamber of

Article

Winston & Strawn LLP | USA | 23 Oct 2017

District Court Invalidates Portion of Anti-Inversion Regulations

On September 29, 2017, a federal district court in Texas granted a motion for summary judgment and set aside as unlawful the government's

Article

Vinson & Elkins LLP | USA | 9 Oct 2017

District Court Invalidates Section 7874 Inversion Regulation and Opens Door for Challenges of Certain Temporary Regulations

On September 29, 2017, the United States District Court for the Western District of Texas struck down Temporary Treasury Regulations 1.7874-8T (the

Article

McGuireWoods LLP | USA | 29 Aug 2017

Where Things Stand: Review of Key Issues Facing Congress This Fall

We hope everyone has had a chance to relax over August recess because things are about to heat up again on Capitol Hill. McGuireWoods’ tax policy

Article

Crowell & Moring LLP | USA | 23 May 2017

District Court Upholds FinCEN Rule Imposing Special Measures on Tanzanian Bank FBME

On April 14, 2017, the U.S. District Court for the District of Columbia upheld the Treasury Department’s use of Section 311 of the USA PATRIOT Act to

Article

Baker McKenzie | USA | 21 Jul 2016

DHS publishes interim rule on petitions for rulemaking

On July 21, 2016, the Department of Homeland Security (DHS) published in the Federal Register an interim final rule Docket No. DHS-2009-0009

Article

McDermott Will & Emery | USA | 5 Jul 2016

Commissioner Files Opening Brief in Ninth Circuit Appeal of Altera

In Altera Corp. v. Commissioner, 145 T.C. No. 3 (July 27, 2015), the Tax Court, in a unanimous reviewed opinion, held that regulations under Section

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