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Carter Ledyard & Milburn LLP | USA | 10 May 2022

Update on Issue 2022-2 Regarding GRATs

Issue 2022-2 discussed CCA 201939002 which took the position that a zeroed-out GRAT was invalidated as a result of a failure to disclose relevant…
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Golding & Golding, International Tax Lawyers | USA | 7 Feb 2022

Penalty Relief for Failure to Report Foreign Trusts: Forms 3520-A & 3520

In recent years, the Internal Revenue Service has significantly increased enforcement of the Form 3520-A Reporting Requirements. Under the Internal…
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McDermott Will & Emery | USA | 15 Dec 2021

Tax Court Orders Are Searchable (Again)

In late 2020, the US Tax Court transitioned to a new case management system, DAWSON (Docket Access Within a Secure Online Network), which was named…
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McDermott Will & Emery | USA | 23 Nov 2021

Special Trial Judge Receives Tax Court’s Highest Award

On November 21, 2021, the US Tax Court announced that Special Trial Judge Daniel A. Guy, Jr., received the J. EDGAR Murdock Award for his…
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Crowell & Moring LLP | USA | 4 May 2021

Patent litigation fees deductible, Tax Court Rules

In good news for generic drug manufacturers, the U.S. Tax Court recently ruled that they can deduct legal fees associated with patent infringement…
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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…
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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…
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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)…
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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…
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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…
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