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Mayer Brown | USA | 12 Sep 2023
Blowing the Whistle on Transfer Pricing
In a recent case, Villa-Arce v. Commissioner, a whistleblower sent information to the IRS that he believed showed that the company was using…
Golding & Golding, International Tax Lawyers | USA | 24 Aug 2023
Challenging IRS International Assessable Reporting Penalties
When it comes to international information reporting penalties, the Internal Revenue Service does not play fairly. That is because international…
Crowell & Moring LLP | USA | 3 Aug 2023
The Tax Court Petition Deadline Is Long Gone and There Was Nothing Else I Could Do: A Feeling Some Taxpayers Know All Too Well
Until last year, when a taxpayer filed a petition late with the Tax Court in either a deficiency or collection due process (CDP) case, the Tax Court…
Mintz | USA | 24 Jul 2023
Tax Court Case Watch: Tax Court Considers the Application of the Self-Employment Tax Rules to Investment Funds
Sponsors of investment partnerships should be aware that the IRS is aggressively challenging management structures designed to qualify for the…
Mintz | USA | 18 Jul 2023
Tax Court Confirms that Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure
A recent US Tax Court decision confirmed that taxpayers can benefit from the “profits interest” safe harbor, set forth in Revenue Procedures 93-27…
Eversheds Sutherland (US) LLP | European Union, USA | 13 Jun 2023
Global viewpoints on Transfer Pricing litigation
Members of our Global Transfer Pricing team continue their 2023 webinar series focused on various Transfer Pricing issues and topics. For the third…
Shearman & Sterling LLP | USA | 18 May 2023
Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure
On May 3, 2023, the Tax Court released a Memorandum Opinion in ES NPA Holding LLC v. Commissioner holding that the taxpayer’s indirect receipt of a…
Dentons Bingham Greenebaum LLP | USA | 15 May 2023
Indiana Tax Developments: Spring 2023
Authorizes certain pass through entities to elect to pay tax at the entity level based on each owner’s share of adjusted gross income. Senate…
Skadden Arps Slate Meagher & Flom LLP | USA | 11 May 2023
Tax Court Holds Indirect Grant of Profits Interest To Be Non-Taxable, Citing IRS Guidance
On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership…
McDermott Will & Emery | USA | 25 Apr 2023
Tax Court Tells IRS It Cannot Assess or Collect Certain Tax Penalties
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory…
