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  • 2009 UCLA Extension Annual Tax Controversy Conference

    October 27, 2009
    The firm will be sponsoring the 2009 UCLA Extension Annual Tax Controversy Conference on October 27 in Beverly Hills. New York Partner Larry Hill will be speaking on the “Representation Techniques: From Examination to Tax Court Litigation” panel.
  • Focus on Tax Controversy and Litigation (Volume IV, Issue 9)

    November 30, 2011

    In this issue:

    • LB&I Provides Examination Procedures for Uncertain Tax Position Statements
    • IRS May Seek Electronic Metadata
    • IRS Asserts Hedging Treatment to Deny Taxpayer Claimed Ordinary Treatment on Derivative Modification
    • New Manual Transmittal on FBAR Penalties
    • California Court Issues Tentative Statement of Decision Finding that 50-Percent Tax Shelter Promoter Penalty Does Not Apply Retroactively
    • OECD Requests Comments Related to Permanent Establishment
    • Swiss Parliamentary Committee Approves Amendments to US-Switzerland Tax Treaty
    • “FTC Generator” Case Update

    New York

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 8)

    October 31, 2011

    In this issue:

    • Supreme Court Grants Certiorari to Settle Circuit Split on Basis Overstatement
    • Internal Revenue Service Offers Insight Regarding Application of Codified Economic Substance Doctrine
    • Chief Counsel Notice Addresses Settlement Offers Designed to Avoid the Valuation Misstatement Penalty
    • Taxpayers Argue District Court Erred in Dismissing Damages Suit on Unauthorized Disclosures Made under US-Japan Tax Treaty
    • Third Circuit Vacates Tax Court’s Jurisdictional Holding in Sunoco
    • Two Julius Baer Financial Advisors Charged in US Tax Evasion Probe
    • Draft Instructions to FATCA Reporting Form Released

    New York

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 7)

    September 28, 2011

    In this issue:

    • Ninth Circuit Affirms Tax Court in Samueli
    • District Court Rules Closing Agreements Left Door Open to Adjust NOL Limitation
    • Swiss Banks Provide Statistical Data on US Taxpayers in Connection with Tax Evasion Investigation
    • IRS Releases Guidance to Compliance Assurance Process Teams for Evaluating Uncertain Tax Position Statements
    • Proposed Treasury Regulations Would Explicitly Add Credit Default Swaps to Notional Principal Contract Definition
    • Tax Court Applies Substance-Over-Form and Step Transaction Doctrines to So-Called “DAD” Transaction, Upholds Penalty in Superior Trading
    • Final Regulations Issued on Penalties for Failure to Disclose Reportable Transactions

    New York

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 6)

    September 2, 2011

    In this issue:

    • Supreme Court Asked to Resolve Split on Whether Basis Overstatement Extends Statute of Limitations
    • Switzerland Concludes Withholding Tax Agreements with Germany, United Kingdom
    • Ninth Circuit Holds that Fifth Amendment Does Not Apply to Foreign Bank Account Records
    • Tax Court Holds Lack of Economic Substance Will Not Bar Valuation Misstatement Penalty
    • Treasury Department Issues Final Regulations on Abatement of Penalties and Interest

    New York

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 5)

    July 29, 2011

    In this issue:

    • Guidance Released for IRS Field Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties
    • IRS Issues Phased-in Timeline for FATCA Implementation
    • IRS Releases New “Frequently Asked Questions” For Schedule UTP Reporting
    • D.C. Circuit Has Authority to Consider APA Challenge to IRS Notice
    • Federal Court Allows Depositions of IRS Agents in Summons Enforcement Proceeding
    • IRS Finalizes FTC Regulations
    • IRS Releases Proposed Guidance on Ex Parte Communications Between Appeals and Other IRS Employees
    • Swiss Bankers Charged with Helping Americans Evade US Taxes

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 4)

    June 30, 2011

    In this issue:

    • FinCEN and IRS Extend FBAR Filing Deadlines for Certain Individuals; TEI and SIFMA Request Guidance and Extension for FATCA Compliance
    • Field Agents Will Not Initially Receive Schedule UTP, IRS Expects to Release Additional “Frequently Asked Questions”
    • Third Circuit Holds Swap-and-Assign Transaction Was Disguised Loan
    • Turning the Tide of Section 6501(e)(1)(A) Cases
    • Tax Court Holds It Does Not Have Jurisdiction to Review IRS’s Decision Not to Investigate a Whistleblower Claim
    • IRS Grants Extension to Certain Taxpayers, Updates FAQ on 2011 Offshore Voluntary Disclosure Initiative
    • IRS Finalizes Proposed Regulations Regarding Circular 230
    • Federal Court Finds Attorney-Client Privilege Not Waived by Production of Opinion Letter

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 3)

    May 27, 2011

    In this issue:

    • Switzerland Sued by UBS Clients in European Court of Human Rights; Swiss Parliament Approves Twelve Revised Double Taxation Treaties
    • IRS Pursues Individual After “Silent Disclosure” of Interest in Offshore Account
    • IRS Officials Discuss 2011 Offshore Voluntary Disclosure Initiative
    • U.S. Tax Court Adopts Amendments to Its Rules of Practice and Procedure
    • IRS Addresses Taxpayer Concerns Regarding Uncertain Tax Position Disclosure Requirements; Financial Accounting Foundation Announces Evaluation of Uncertain Tax Position Accounting Rules

  • Focus on Tax Controversy and Litigation (Volume IV, Issue 2)

    May 2, 2011

    In this issue:

    • IRS Issues Supplemental FATCA Guidance Addressing Certain International Concerns Without Significantly Easing the Burden of Compliance, Seeks Additional Public Input
    • Compliance Assurance Process Program Expanded and Made Permanent
    • Neither Mayo nor Final Treasury Regulations Persuade Tax Court to Apply Extended Statute of Limitations in a So-Called Son of BOSS Transaction Case
    • IRS to Rely on Valuations Provided to the SEC
    • Court Denies Taxpayer’s Motion for Partial Summary Judgment Pending Further Discovery in Case Involving So-Called “FTC Generator” Transaction
    • IRS Seeking Bank Records of US Resident Accountholders at Foreign Bank
    • On Remand, Court of Federal Claims Finds It Lacks Jurisdiction to Determine Penalties in Jade Trading

  • Focus on Tax Controversy and Litigation (Volume III, Issue 3)

    May 27, 2010

    In this issue:

    • War on Tax Fraud and in Afghanistan: Who Knew They Were Linked?
    • IRS Issues New Transitional Rules for Taxation of Substitute Dividends
    • Textron Submits Reply Brief, but Supreme Court Denies Certiorari
    • Tax Court Rules Foreign Currency Options Are Not Section 1256 Contracts, Taxpayer’s Major/Minor Transaction Fails to Generate Loss
    • Delaware Court Upholds Use of Shareholder Rights Plan to Protect NOLs
    • United Kingdom Tribunal Grants Treaty Relief to Investor in Delaware LLC
    • Swiss People’s Party Announces Support for UBS Pact
    • Treasury and IRS Officials Discuss Prospective FATCA Guidance
    • Employment Tax Audit Program to Ignore Coordinated Industry Cases