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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


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


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


Roberts & Holland LLP | USA | 12 Aug 2019

The Nondelegable Duty to Ensure Returns are Filed

Most of the civil penalties that may be assessed against a taxpayer by the IRS for failures relating to the filing of tax returns or payment of taxes


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


Castro & Co | USA | 9 Jul 2019

Pursuing a Claim of Refund in Federal Court

The first step in filing a claim for refund against the IRS is to file either a Form 1040X, Amended U.S. Federal


McDermott Will & Emery | USA | 29 May 2019

Tax Court Announces Limited Entries of Appearance

The concept of limited scope representation is not a new one in the legal arena. Rule 1.2(c) of the ABA Model Rules of Professional Conduct provides

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