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Greenberg Traurig LLP | USA | 26 Oct 2020

Second Round of Micro-Captive Insurance Settlements Provides Stricter Terms

On Oct. 22, 2020, the IRS announced it is offering a second time-limited settlement initiative to certain taxpayers who participated in abusive…

Caplin & Drysdale, Chartered | USA | 21 Sep 2020

IRS Kicks Off Post-Altera Audit Adjustments

Taxpayers with cost sharing arrangements (“CSAs”) can again expect close audit scrutiny—and potential Adjustments—related to their treatment of…

McDermott Will & Emery | USA | 23 Mar 2020

US Tax Court Cancels Remainder of Spring Trial Sessions

After cancelling several trial sessions for March 2020 and April 2020, and closing its building until further notice, the US Tax Court (Tax Court)…

Holland & Knight LLP | USA | 10 Feb 2020

Tax Affecting Part 2 What Rate to Use

In Part 1, the concept and rationale of tax affecting was discussed. Tax affecting the earnings is considered necessary to match the derived discount…

Schulte Roth & Zabel LLP | USA | 5 Dec 2019

First Circuit Court of Appeals Finds Private Equity Funds Not Liable for Pension Liabilities of Portfolio Company

The Court of Appeals for the First Circuit (“First Circuit”) ruled on Nov. 22, 2019 that separate private equity funds (“Sun Funds”) managed by Sun…

Kramer Levin Naftalis & Frankel LLP | USA | 30 Oct 2019

Target Not Permitted to Deduct Finder’s Fee Incurred in Connection with Its Acquisition

Transaction expenses, including fees for legal counsel, accountants, financial advisors, brokers and other third parties, are an ineluctable aspect…

Castro & Co | USA | 8 Oct 2019

Step-by-Step Guide to Challenging the Validity of a Treasury Regulation

One question that comes up quite often with our clients is why some of our legal positions are contrary to established Treasury Regulations. Yes, it…

McGuireWoods LLP | USA | 12 Aug 2019

Recent Cases of Interest to Fiduciaries

A beneficiary who received notice but did not participate in litigation between another beneficiary and The Trustees found herself with no recourse…

Michael Best & Friedrich LLP | USA | 12 Aug 2019

Gourmet Dining - Not A Typical Tax-Exempt Use

The Ursino Steakhouse and Tavern in Union, New Jersey is an upscale restaurant serving prime steaks, lobster bisque and an entire wine room full of…

Ropes & Gray LLP | USA | 12 Aug 2019

Altera Aftermath: IRS Lifts Moratorium on Examining Stock-Based Compensation Cost-Sharing Arrangements

In the wake of the IRS' Ninth Circuit victory in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Circuit 2019), the IRS' Large Business and…
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