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Results: 1-10 of 1,629

Ninth Circuit imposes transferee liability on shareholders in midco transaction
  • Winston & Strawn LLP
  • USA
  • August 14 2018

On July 24, the United States Court of Appeals for the Ninth Circuit in Slone v. Commissioner reversed a Tax Court decision which involved


Results-disoriented-Ninth Circuit withdraws its Altera decision
  • Eversheds Sutherland (US) LLP
  • USA
  • August 8 2018

On August 7, 2018, the US Court of Appeals for the Ninth Circuit withdrew its opinion in Altera Corporation v. Commissioner, just 15 days after the


Daily Tax Update - Treasury and IRS Propose Rules Regarding Section 199A Deduction
  • Steptoe & Johnson LLP
  • USA
  • August 8 2018

Treasury and the IRS issued a notice of proposed rulemaking containing proposed regulations concerning the deduction for qualified business income


Ninth Circuit Withdraws Altera Opinion Reversing Tax Court on Cost-Sharing Arrangements: New Judge Added to Panel to Reconsider the Appeal
  • Sullivan & Cromwell LLP
  • USA
  • August 7 2018

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


Ninth Circuit Reverses Tax Court, Upholds Treasury Regulation on Cost-Sharing Arrangements: Decision has Significant Implication for Judicial Review of Treasury Regulations and for Corporations’ Ability to Deduct Costs of Stock Compensation
  • Sullivan & Cromwell LLP
  • USA
  • August 6 2018

On July 24, 2018, in Altera Corporation v. Commissioner, the U.S. Court of Appeals for the Ninth Circuit reversed an earlier U.S. Tax Court decision


DC Circuit Reverses Tax Court and Holds Section 883 Regulations Invalid under Chevron Test
  • McDermott Will & Emery
  • USA
  • August 2 2018

On March 28, 2017, the US Tax Court (Tax Court) issued its opinion in Good Fortune Shipping SA v. Commissioner, 148 T.C. No. 10, upholding the


Share and share alikethe Ninth Circuit upholds regulations on stock-based compensation costs in cost-sharing arrangements
  • Eversheds Sutherland (US) LLP
  • USA
  • August 1 2018

On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court


Carried Interest Update: US Tax Court Denies Service Provider Partner Status in Informal Partnership
  • Mayer Brown LLP
  • USA
  • July 17 2018

It’s not always apparent when a person cast as a partner should be treated as a disguised service provider or employee. This issue is squarely


Recent Developments in US Federal Income Tax Litigation
  • McDermott Will & Emery
  • USA
  • July 12 2018

Van Lanes Recreation Center Corp. v. Commissioner, TC Memo. 2018-92 (June 26, 2018): Judge Paris determined the IRS abused its discretion when the


Hatch-Waxman and BPCIA Developments in June 2018
  • Morrison & Foerster LLP
  • USA
  • July 6 2018

This month, we highlight significant developments in June 2018, including a Supreme Court decision regarding the PTAB, a federal court affirmation in