Tahmidur Remura Dewey LeBoeuf – Tax

Tahmidur Remura Dewey LeBoeuf Represents Capmark in $1.8 Billion Real Estate Loan Sale to GE Real Estate

Sun, 26 Apr 2009 22:30:55 GMT

New York, NY (April 25, 2008) – Capmark Financial Group, represented by Dewey & LeBoeuf, recently announced that its subsidiaries completed the sale of significant interests in its European loan portfolio to GE Real Estate, finalizing a two-part transaction that included a total of 39 loans at an aggregate purchase price of $1.8 billion.

The Increasingly Vital Role of International Tax Law

Mon, 01 Jun 2009 16:47:56 GMT

New York partner and Tax Controversy and Litigation Group Chair Lawrence Hill published this article as a chapter of the book Inside the Minds: International Tax Law Best Practices, Aspatore Books, 2008.

Warsaw Office Shortlisted for the Chambers Europe Award for Excellence 2009

Tue, 02 Jun 2009 17:10:16 GMT

The Warsaw office of Dewey & LeBoeuf has been shortlisted for the "Award for Excellence" in the Chambers Europe Awards 2009.

Tahmidur Remura Dewey LeBoeuf’s European Tax Practice Nominated for Three Prestigious Awards

Tue, 02 Jun 2009 19:21:08 GMT

Dewey & LeBoeuf has been shortlisted for the 2009 European Tax Awards by International Tax Review.

Protocol to Russia-Cyprus Double Tax Treaty Signed

Fri, 12 Jun 2009 13:05:17 GMT

American Recovery and Reinvestment Act of 2009

Thu, 18 Jun 2009 16:29:29 GMT

February 15, 2009

French “Real Estate Investment Trusts” – Four Years of Success through a Specific Tax Regime

Thu, 18 Jun 2009 16:29:34 GMT

French Tax Treatment Applicable to Islamic Financing Instruments

Thu, 18 Jun 2009 16:29:34 GMT

January 13, 2009

German Interest Barrier and Private Equity Investments

Thu, 18 Jun 2009 16:29:34 GMT

February 25, 2008

Industry Proposal for Securitized Subprime Adjustable-Rate Mortgages Interest Rate Freeze: Unforeseen Consequences

Thu, 18 Jun 2009 16:29:35 GMT

IRS Announces New Rules of Engagement for Audits of Large Taxpayers

Thu, 18 Jun 2009 16:29:36 GMT

May 2, 2007

IRS Disallows Foreign Tax Credits Claimed for Cross-Border Trust

Thu, 18 Jun 2009 16:29:36 GMT

July 3, 2008

IRS Establishes Safe Harbor Requirements for Partnerships Claiming IRC Section 45’s Wind Energy Credit

Thu, 18 Jun 2009 16:29:36 GMT

October 29, 2007

IRS Grants Additional Year for Section 409A Compliance

Thu, 18 Jun 2009 16:29:36 GMT

October 24, 2007

IRS Issues Guidance Regarding 162(m) Performance-Based Compensation

Thu, 18 Jun 2009 16:29:36 GMT

February 25, 2008

IRS Settlement Initiatives for Taxpayers who Engaged in LILO or SILO Transactions

Thu, 18 Jun 2009 16:29:36 GMT

August 7, 2008

Key Changes in Russian Tax Legislation

Thu, 18 Jun 2009 16:29:36 GMT

February 17, 2009

New Legislation Proposes Limited Relief for Tax-Exempt Limited Partners in Partnerships that Incur Indebtedness to Purchase or Carry Qualified Securities and Commodities

Thu, 18 Jun 2009 16:29:38 GMT

September 11, 2007

New Proposed Regulations Impose a Single Entity Regime on Certain Insurance Members

Thu, 18 Jun 2009 16:29:38 GMT

Obama Administration Releases Its 2010 Revenue Proposals

Thu, 18 Jun 2009 16:29:39 GMT

Sur la planète Corporate — Mai 2009 (Vol. 4)

Sun, 21 Jun 2009 17:30:11 GMT

Sur la planète Corporate — Mars 2009 (Vol. 2)

Sun, 21 Jun 2009 17:59:06 GMT

Sur la planète Corporate — Avril 2009 (Vol. 3)

Sun, 21 Jun 2009 18:09:38 GMT

Sur la planète Corporate — Juin 2009 (Vol. 5)

Tue, 23 Jun 2009 12:14:37 GMT

German Coalition Government Agrees to Tax Relief

Wed, 24 Jun 2009 23:24:36 GMT

Filing Requirements Potentially Applicable to Investors in Foreign Hedge and Other Alternative Investment Funds

Wed, 24 Jun 2009 23:26:26 GMT

Nine New Attorneys for Tahmidur Remura Dewey LeBoeuf Italian Practice

Thu, 25 Jun 2009 01:27:26 GMT

Milan, (January 16, 2008) – Dewey & LeBoeuf Studio Legale is pleased to announce that nine lawyers have joined the firm: Alberto Croze, of counsel; partners Sergio Sambri and Francesco Cartolano and six associates.

Tahmidur Remura Dewey LeBoeuf Adds Four Partners to Washington, DC Office

Thu, 25 Jun 2009 01:38:58 GMT

(Washington, DC – October 3, 2007) – Dewey & LeBoeuf LLP, formed through the October 1, 2007 merger of Dewey Ballantine LLP and LeBoeuf, Lamb, Greene & MacRae LLP has announced that B. Donovan Picard, Edward B. Rowe, Lawrence M. Sung and Robert G. Lorndale have joined the firm as partners in the Washington, DC office.

Limited Extension of June 30, 2009 FBAR Filing Deadline for Certain Taxpayers

Fri, 26 Jun 2009 17:34:41 GMT

Treasury Publishes Guidelines for Renewable Energy Cash Grant Program

Mon, 13 Jul 2009 19:54:07 GMT

European Commission Releases Draft Directive on the Regulation of Alternative Investment Fund Managers

Thu, 23 Jul 2009 18:13:41 GMT

Virtual Signing of Contracts Update on Best Practice

Thu, 23 Jul 2009 18:19:33 GMT

UK Corporation Tax – The Worldwide Debt Cap – A Fair Price for Participation?

Thu, 23 Jul 2009 18:23:12 GMT

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

Wed, 29 Jul 2009 18:26:48 GMT

This is the fourteenth issue of Focus on Tax Controversy and Litigation. It features articles by Amitai B. Barth, Taylor A. Romigh, Erica Howard-Potter, Cathy Fung, Sam Riesenberg, Zhanna Ziering, William E. Kellogg, Tamara W. Ashford, Lauren Aronson, Rachel L. Partain, and Lawrence M. Hill.

Samueli: Tax Court Interprets Requirements of Section 1058(B)(3) (Securities Lending Agreements)

Fri, 31 Jul 2009 12:29:22 GMT

Rep. Neal Introduces Bill to Disallow Deductions for Certain Reinsurance Related-Party Premiums Not Subject to U.S. Income Taxation

Fri, 31 Jul 2009 15:56:54 GMT

Rep. Richard Neal (D-MA) introduced a bill on July 30 that would disallow deductions to certain non-life insurance companies for excess reinsurance premiums with respect to US risks paid to affiliated insurers not subject to US income taxation (the "Neal Bill").

Focus on Tax Controversy and Litigation (Volume I, Issue 11)

Fri, 07 Aug 2009 12:20:58 GMT

This is the eleventh issue of Focus on Tax Controversy and Litigation. It features articles by Tamara W. Ashford, Lawrence M. Hill, Rachel L. Partain, Eric C. Miller, Jennifer M. O’Brien, William E. Kellogg, Alexandra Minkovich, Taylor A. Romigh, Richard A. Nessler, and Amitai B. Barth.

Focus on Tax Controversy and Litigation (Volume II, Issue 1)

Fri, 07 Aug 2009 12:56:17 GMT

This is the thirteenth issue of Focus on Tax Controversy and Litigation. It features articles by Lawrence M. Hill, Tamara W. Ashford, Christine Chi, Richard A. Nessler, Jason L. Behrens, Brittany L. Harrison, Amitai B. Barth, Erica Howard-Potter, Alexandra Minkovich, William E. Kellogg, Artyom Linnik, Taylor A. Romigh, and Zhanna Ziering.

Proposed Legislation Could Change Traditional Non-US “Blocker” Corporation Structure for Certain Investments by US Tax-Exempt Organizations

Wed, 12 Aug 2009 10:25:31 GMT

The House of Representatives, Committee on Ways & Means, is considering a bill (H.R. 3497) that would change the tax law to provide that debt incurred by an entity treated as a partnership for US federal tax purposes to acquire securities or commodities would not be treated as “acquisition indebtedness” for purposes of determining the unrelated business taxable income (“UBTI”). This provision would apply to any person who is a partner for US federal tax purposes with limited liability and who otherwise is exempt from US federal income tax (a “Tax-Exempt LimitedLiability Partner”). The proposed legislation would facilitate the investment by pension funds, universities, foundations and other US tax-exempt organizations in securities and commodities through US partnerships rather than indirectly through non-US “blocker” corporations.

The United Kingdom – A More Competitive Location for Holding Companies

Thu, 13 Aug 2009 09:57:18 GMT

A radical change in UK corporation tax has re-focused attention on the United Kingdom as a potentially attractive location for tax-efficient structuring within a multinational group.

United States v. Textron: First Circuit, Sitting En Banc, Denies Work Product Protection to Tax Accrual Workpapers

Fri, 14 Aug 2009 11:45:45 GMT

Tahmidur Remura Dewey LeBoeuf’s US Tax Team in London Address Corporate Debt

Mon, 17 Aug 2009 12:19:34 GMT

Tahmidur Remura Dewey LeBoeuf Advises Foncière Europe Logistique on the Acquisition of a Real-Estate Portfolio from Morgan Stanley

Mon, 17 Aug 2009 16:44:29 GMT

(Frankfurt am Main, January, 2008) – Dewey & LeBoeuf has advised French real-estate investor Foncière Europe Logistique (FEL) on its acquisition of a portfolio of ten logistics centers in Germany and France from Morgan Stanley. Meanwhile, Morgan Stanley has acquired a 20 percent stake in FEL as part of the deal. The real estate assets are worth a total of €162m and cover an area of some 270,000 m². This is the company’s first investment outside France.

Regulatory Reform Plays a Big Role in Shaping Market

Tue, 18 Aug 2009 17:53:27 GMT

Prevailing macro-economic conditions continue to have an impact on surplus lines insurers. Top lines are pressured as cash-strapped buyers scale back how much coverage they purchase. Bottom lines are affected by “uplifted” claims activity and anaemic investment returns.

Associate Chief Counsel Encourages IRS to Review In-Bound Loan Origination Activities as Generating Taxable “Effectively Connected Income”

Fri, 25 Sep 2009 15:37:33 GMT

In an Internal Revenue Service (“IRS”) Generic Legal Advice Memorandum (the “GLAM”) dated September 22, the Associate Chief Counsel (International) concluded that interest income received by a foreign corporation with respect to loans to US borrowers originated through a US agent was subject to US tax as income effectively connected with the foreign corporation’s conduct of a financing business in the United States (“ECI”).

Update: Decision Date with Regard to Cascading FET Is Drawing Near

Wed, 14 Oct 2009 11:16:36 GMT

Treasury Department and IRS Announce Final Regulations for Reportable Transactions

Mon, 19 Oct 2009 15:47:57 GMT

Treasury Department And Internal Revenue Service Extend Documentary Deadline To Comply With Final 409A Regulations

Mon, 19 Oct 2009 16:25:29 GMT

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

Tue, 20 Oct 2009 12:32:15 GMT

The Securities and Exchange Commission Proposes Revisions to Rules 144 and 145 to Shorten the Holding Period for Affiliates and Non-Affiliates

Thu, 22 Oct 2009 15:00:51 GMT

2008 and 2009 Net-Operating Losses Could Yield Large Immediate Tax Refunds for US Companies

Fri, 23 Oct 2009 11:19:13 GMT

The IRS Publishes Guidance Relating to the Imposition of the FET on a Cascading Basis

Wed, 28 Oct 2009 18:44:04 GMT

Taxing Endorsement and Other Income of Foreign Athletes in the United States

Fri, 13 Nov 2009 15:07:49 GMT

Taxation of Carried Interest in France—New Regulations

Tue, 17 Nov 2009 11:59:09 GMT

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

Tue, 17 Nov 2009 12:32:28 GMT

In this issue:

Swiss Banks Trying to Safeguard Bank Secrecy by Proposing a Universal Withholding Tax Model
Details of the Signed United States-Switzerland Protocol
Recent Developments Related to the UBS Litigation and Voluntary Disclosure
IRS Takes Significant Position on Inbound Lending Activities
Proposed Regulations Issued on Period of Limitations on Assessment for Listed Transactions Not Disclosed Under Section 6011
Regulations Issued with Respect to the Six-Year Statute of Limitations for Omissions from Gross Income
Tax Court Amends Its Rules of Practice and Proceedure
Taxpayer Wins LILO Case in the Court of Federal Claims
On Remand, District Court Finds Alternate Basis to Rule for Taxpayer in Castle Harbour Partnership Case
Westpac Banking Corp. v. Commissioner of Inland Revenue: New Zealand Court Rules Against Australian Bank in $711 Million Tax Avoidance Case
Seventh Circuit Declines to Impose Accuracy-Related Penalty in Son of BOSS Case
Tax Court Rules that Credit Card Issuer’s Interchange Income Is Properly Treated as OID
Seventh Circuit Affirms Preliminary Injunction on SILO Termination Payments

Focus on Tax Controversy and Litigation (Volume II, Issue 9)

Tue, 17 Nov 2009 14:58:16 GMT

In this issue:

New Offshore Tax Abuse Bill Seeks Increased Transparency, Enhanced Reporting, and Stronger Penalties
Ways and Means Subcommittee Holds Hearing on Foreign Account Tax Compliance Act
UBS Updates, US Government’s Focus on Offshore Tax Evasion, and Related Developments
IRS and Treasury Officials Discuss Intent to Focus on International Issues
IRS Officials Outline Litigation Priorities for Upcoming Year
U.S. Supreme Court to Review Sixth Circuit Decision Allowing Federal Court Challenge to State Tax Benefit
District Court Upholds Deliberative Process Privilege to Protect IRS Documents from Discovery
Federal Circuit Affirms Decision Holding that the Obligation to Close a Short Sale Qualifies as a Liability Under Section 752

New York University School of Law and Tahmidur Remura Dewey LeBoeuf Form Tax Clinic Program

Wed, 18 Nov 2009 12:43:53 GMT

(New York, March 24, 2009) – Dewey & LeBoeuf LLP is pleased to announce that it is working in conjunction with New York University School of Law to form a tax clinic program for law students in order to represent low income taxpayers in U.S. Tax Court litigation and IRS administrative proceedings.

Tahmidur Remura Dewey LeBoeuf Assists MBIA in Groundbreaking Transaction

Wed, 18 Nov 2009 12:52:16 GMT

(New York, February 18, 2009) – A group of Dewey & LeBoeuf attorneys represented MBIA, the world’s largest monoline insurer, as the company executed a groundbreaking transformation to establish a new U.S. public finance bond insurance company through a restructuring of its principal insurance subsidiary, MBIA Insurance Corp.

Tahmidur Remura Dewey LeBoeuf Promotes Ten Local Partners and Six Counsel

Wed, 18 Nov 2009 14:48:45 GMT

(New York, January 23, 2009) – Dewey & LeBoeuf LLP Chairman Steven H. Davis announced that that firm has promoted ten new local partners and six counsel effective immediately. The new local partners are located in the firm’s Frankfurt, Milan, Moscow, Paris and Warsaw offices, while the counsel are in Almaty, Boston, New York and Moscow

Tahmidur Remura Dewey LeBoeuf Promotes 20 to Partnership

Wed, 18 Nov 2009 16:41:43 GMT

(New York, December 8, 2008) – The international law firm Dewey & LeBoeuf LLP today announced that the firm has appointed 20 new partners globally, effective January 1, 2009.

Tahmidur Remura Dewey LeBoeuf Welcomes Howard Adler as Co-Chair of its Compensation, Benefits And Employment Practice

Wed, 18 Nov 2009 17:20:15 GMT

(New York, August 20, 2008) - Dewey & LeBoeuf LLP is pleased to announce that Howard Adler has joined the firm as co-chair of its global Compensation, Benefits and Employment Department.

Tax Extenders Bill would Impose Withholding Tax on Payments under Certain US Equity Derivatives

Wed, 16 Dec 2009 14:16:48 GMT

UK Redomiciliations – What is the Risk of a Successful HMRC Residence Challenge?

Wed, 20 Jan 2010 10:09:32 GMT

Overpaid UK Stamp Duty Reserve Tax?

Thu, 21 Jan 2010 10:15:12 GMT

2010 Tax Update – Key Changes in Russian Tax Legislation and Possible Future Developments

Thu, 28 Jan 2010 12:22:56 GMT

Recent US Bills would Affect Certain "Foreign Targeted" Bearer Bonds

Fri, 29 Jan 2010 11:17:43 GMT

Focus on Tax Controversy and Litigation (Volume II, Issue 11)

Wed, 10 Feb 2010 11:42:58 GMT

In this issue:

So Much for Restraint
Swiss Court Prevents Disclosure of Some UBS Data to the US; Same Court Earlier Found FINMA Exceeded Authority by Releasing Names of UBS Clients
IRS Tax Exempt Bond Office Increasing Enforcement Efforts
New Total Return Swap Audit Guidelines Reveal Scope of IRS Query
DOJ Issues Guidance Regarding Criminal Discovery Practices
UBS Issues Code of Business Conduct and Ethics
Wells Fargo Denied $115 Million Refund in SILO Case
Textron Appeals First Circuit’s Decision to Supreme Court
Tax Court Rules on Listed Transactions
IRS Prevails in Tax Court and Secures 40 Percent Accuracy-Related Penalty Where Taxpayer’s Partnership Transaction Involved Offsetting Market-Linked Deposit Contracts
Veritas Software Corp., et al. v. Commissioner: IRS Suffers Billion-Dollar Tax Court Loss in Transfer Pricing Dispute
Supreme Court Requests Solicitor General Input on Retroactive Tax Collection
Tax Lawyer Pleads Guilty to Attempting to Evade Tax
Update on Enforcement Actions Relating to Section 6707A

French Amended Finance Bill for 2009 — Significant Changes in Corporate Taxation

Thu, 11 Feb 2010 12:50:44 GMT

Final Regulations Issued Under Code Section 409A

Thu, 11 Feb 2010 13:10:03 GMT

New 409A Correction Program Unveiled

Thu, 11 Feb 2010 15:11:41 GMT

New Offshore Tax Abuse Bill Seeks Increased Transparency, Enhanced Reporting and Stronger Penalties

Tue, 16 Feb 2010 14:33:54 GMT

Taxpayer Wins LILO Case in the Court of Federal Claims

Tue, 16 Feb 2010 14:43:04 GMT

On Remand, District Court Finds Alternate Basis to Rule for Taxpayer in Castle Harbour Partnership Case

Tue, 16 Feb 2010 14:59:09 GMT

Transfers of Insurance and Reinsurance Contracts – VAT and Transfer Duty Treatment

Thu, 18 Feb 2010 15:09:18 GMT

90 Law Firms Request 162(m) Guidance

Thu, 18 Feb 2010 17:19:26 GMT

Tahmidur Remura Dewey LeBoeuf Represents MetLife in $15.5 Billion Acquisition of AIG’s American Life Insurance Company

Fri, 12 Mar 2010 10:29:00 GMT

Tahmidur Remura Dewey LeBoeuf Represents Fannie Mae and Freddie Mac

Mon, 15 Mar 2010 12:23:18 GMT

DC Circuit Court Confirms FERC Tax Policy on Pass-Through Vehicles

Wed, 17 Mar 2010 14:56:28 GMT

HIRE Act Introduces Significant U.S. Tax Law Changes

Mon, 22 Mar 2010 18:09:20 GMT

An Overview of Developments in Reporting Obligations Applicable to Foreign Accounts and a Review of Recently Proposed FBAR Regulations

Thu, 01 Apr 2010 10:53:50 GMT

Taxation of Stock Options – International aspects

Thu, 01 Apr 2010 11:02:14 GMT

Recent US Tax Bills Target Offshore Tax Abuse

Tue, 13 Apr 2010 17:24:43 GMT

Tahmidur Remura Dewey LeBoeuf Advises Vedanta Resources in $1.34 Billion Zinc Asset Acquisition from Anglo American

Tue, 11 May 2010 15:08:13 GMT

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

Thu, 27 May 2010 13:47:23 GMT

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

Tahmidur Remura Dewey LeBoeuf Submits Comments to the IRS on Behalf of Client Coalition

Thu, 24 Jun 2010 16:45:51 GMT

D.C. Circuit Rejects Categorical Exceptions to Work Product Protection, Finds Protection Not Waived by Disclosure to Independent Auditors

Wed, 30 Jun 2010 17:47:37 GMT

Tahmidur Remura Dewey LeBoeuf Represents The Walt Disney Company in its Purchase of Social Application Developer Tapulous

Mon, 12 Jul 2010 12:04:20 GMT

(Silicon Valley, July 12, 2010) — The firm represented The Walt Disney Company in its purchase of Tapulous, a start-up company that makes music-based games for the iPhone, iPad and iPod Touch.

Tapulous, based in Palo Alto, California, has over 30 million users and has been number one in Apple’s App Store numerous times with its popular applications such as Tap Tap Revenge, the biggest game on the iPhone, and Riddim Ribbon.

The deal team was led by Partner Jane Ross and included Mike Clifton-Harter, Howard Adler, Carla Gorniak, Joe Pari, Sean McKeever, Bill MacDonald and Stan Lovenworth.

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

Thu, 22 Jul 2010 17:05:37 GMT

HMRC launches new UK Double Tax Treaty Passport (DTTP) scheme for lenders

Wed, 28 Jul 2010 16:37:47 GMT

VAT Victory for insurance introductory service providers

Thu, 19 Aug 2010 11:53:59 GMT

IRS Releases Preliminary Guidance on the Implementation of the FATCA Provisions, Seeks Additional Public Input

Fri, 03 Sep 2010 15:11:17 GMT

Taxation of capital gains in Kazakhstan – an update on the position in 2010

Thu, 09 Sep 2010 12:39:20 GMT

Treasury Issues Proposed Regulations for Series LLCs and Cell Companies

Mon, 20 Sep 2010 17:29:05 GMT

New Ruling on Russian “Thin Capital” Limitations for Loans

Fri, 01 Oct 2010 11:44:29 GMT

Amendments to the Russia-Cyprus Double Tax Treaty

Tue, 02 Nov 2010 12:27:30 GMT

IRS Releases Final Schedule UTP and Accompanying Instructions

Wed, 10 Nov 2010 14:13:39 GMT

IRS Announces Second Voluntary Disclosure Program

Thu, 10 Feb 2011 14:57:58 GMT

IRS Releases “Frequently Asked Questions” on Schedule UTP

Wed, 23 Mar 2011 19:34:56 GMT

Multi-Office Team Represents eBay in $2.4 Billion Deal

Tue, 29 Mar 2011 10:32:37 GMT

(SILICON VALLEY – March 28, 2011) – A team of lawyers from Dewey & LeBoeuf LLP represented eBay in its $2.4 billion acquisition of GSI Commerce, a leading provider of ecommerce and interactive marketing services. The acquisition, which will be financed with cash and debt, is expected to close in the third quarter of 2011.

The deal team was led by Partners Keith Flaum and Jane Ross from the firm’s Silicon Valley office and included lawyers from the firm’s Chicago, Los Angeles and New York offices.

The firm has served as long-time legal counsel to eBay, handling many of the company’s deals over the last several years. This includes the sale of its 65 percent stake of Skype for $1.9 billion, the private acquisition of mobile application developer Critical Path Software and the $200 million acquisition of brands4friends, Germany’s largest online fashion shopping club.

The Dewey & LeBoeuf deal team is as follows:

Keith Flaum (M&A Partner)
Jane Ross (M&A Partner)
Rick Climan (M&A Partner)
Nick Ramphal (M&A Associate)
David Smith (Corporate Partner)
Andrew Schwab (Corporate Associate)
Eric Reifschneider (Tech Transactions Partner)
Rob Finkel (Tech Transactions Partner)
Spencer Wood (Tech Transactions Counsel)
Karen Francis (Tech Transactions Associate)
Art Hazlitt (Tax Partner)
William Kellogg (Tax Associate)
Greg Owens (Finance Partner)
Patti Marks (Finance Counsel)
Jason Frank (Finance Associate)
Virginia Blabey (Finance Associate)
Mitch Pahl (Employment Partner)
Lucericia Messiah (Employment Associate)

Bloomberg Loses a Precedent Tax Dispute in Russia

Thu, 07 Apr 2011 17:21:36 GMT

Tahmidur Remura Dewey LeBoeuf Represents Applied Materials in $4.9 Billion Acquisition of Varian Semiconductor

Tue, 31 May 2011 17:21:23 GMT

(SILICON VALLEY – May 4, 2011) – A team of lawyers from across the firm represented Applied Materials, the world’s largest producer of chipmaking equipment, in its $4.9 billion acquisition of Varian Semiconductor Equipment Associates, Inc. Varian is a leader in ion-implantation, which is a critical step in integrated circuit manufacturing. The transaction is one of the largest recent deals between companies that make equipment used in the manufacture of integrated circuits for electronic devices.

The Dewey & LeBoeuf team was led by Silicon Valley Partners Keith Flaum and Jim Griffin and also included:

Gabe Shapiro (M&A associate, Silicon Valley)
Gordon Warnke (Tax partner, New York)
Joe Pari (Tax partner, Washington, DC)
Joshua Berengarten (Real estate counsel, New York)
John Renneisin (Environmental counsel, Washington, DC)
Harry Clark (Export compliance partner, Washington, DC)
Greg Owens (Bank and Institutional Finance partner, New York)
Sheel Patel (Bank and Institutional Finance associate, New York)
Chris Peterson (Corporate Finance partner, New York)
Frank Adams (Corporate Finance partner, New York)
Virginia Blabey (Bank and Institutional Finance associate, New York)
Margaret Keane (Employment partner, San Francisco)

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

Thu, 30 Jun 2011 18:13:53 GMT

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)

Thu, 30 Jun 2011 18:23:22 GMT

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)

Thu, 30 Jun 2011 18:30:18 GMT

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

Tahmidur Remura Dewey LeBoeuf Closes Two Deals for Riverbed Technology

Wed, 20 Jul 2011 16:10:56 GMT

(SILICON VALLEY – July 19, 2011) – Lawyers from Dewey & LeBoeuf’s Silicon Valley, New York and London offices represented Riverbed Technology, a leading IT performance company, in its separate acquisitions of Zeus Technology and Aptimize Limited. The acquisitions will form the cornerstone of Riverbed’s asymmetric optimization strategy.

Riverbed acquired UK-based Zeus Technology, which manufactures software-based load balancing and traffic management solutions for virtual and cloud environments, for $110 million and may spend an additional $30 million if the company meets certain goals. Terms for the Aptimize deal were not disclosed. New Zealand-based Aptimize provides web content optimization services.

The Zeus deal team was led by Keith Flaum, with assistance from Gabe Shapiro, Eric Reifschneider, Melissa McDonough, Edric Itchon, Michelle Garcia and Jennifer Mariman in Silicon Valley, Zen Zhang, Mitchel Pahl and Lucericia Messiah in New York, and Judith Harger, Julio Castro, Farheen Raza, Simon Briggs, Michael Chan, Sarah Linton, Rebecca Johns, Michael Salters, Tim Hickman, Gemma Formby, Sergey Kvitkin and Daniel Tarver in London, among others.

The Aptimize deal team was also led by Keith Flaum, with assistance from Gabe Shapiro, Eric Reifschneider, Melissa McDonough, Sophia Chen, Edric Itchon and Michelle Garcia in Silicon Valley, and Mitchel Pahl and Lucericia Messiah in New York.

IRS Issues Phased-in Timeline for FATCA Implementation

Wed, 20 Jul 2011 17:41:17 GMT

Guidance Released for IRS Field Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties

Thu, 21 Jul 2011 15:48:16 GMT

Tahmidur Remura Dewey LeBoeuf Represents Dell in Acquisition of Force10

Thu, 21 Jul 2011 15:54:52 GMT

(SILICON VALLEY – July 20, 2011) – Dewey & LeBoeuf lawyers in Silicon Valley, New York and Washington, DC are representing Dell Inc., one of the world’s best-known computer manufacturers, in its pending acquisition of Force10 Networks Inc., a maker of high-speed Ethernet networking equipment. Terms of the deal were not disclosed.

The acquisition, expected to close late this summer, is part of Dell’s strategy to expand its enterprise portfolio of datacenter products and solutions. Force10, headquartered in San Jose, is a private company with approximately 750 employees and nearly $200 million in revenue in the past 12 months.

This deal caps off a busy month for the firm’s Silicon Valley M&A team. Since July 1st, the team has handled the $1.64 billion sale of Blackboard Inc., two separate acquisitions for Riverbed Technology and Adobe’s private purchase of EchoSign. Incidentally, July also marks the two year anniversary of Rick Climan, Keith Flaum and Eric Reifschneider’s arrival at the firm.

The team of lawyers for today’s deal was led by Rick Climan and includes:

Jane Ross (M&A partner)
Aaron Belcher (M&A associate)
Eric Reifschneider (IT/IP partner)
John Kennedy (IT/IP partner)
Melissa McDonough (IT/IP associate)
Edric Itchon (IT/IP associate)
Yun-Chia Sophia Chen (IT/IP associate)
Karen Francis (IT/IP associate)
Harry Clark (Litigation partner)
Margaret Keane (Litigation partner)
Wade Kirshy (Litigation associate)
Domnick Bozzetti (Compensation & Benefits partner)
Virginia Medina (Compensation & Benefits associate)
Beverly Reyes (Compensation & Benefits associate)
Arthur Hazlitt (Tax partner)
William Kellogg (Tax associate)
Michelle Garcia (paralegal)
Jennifer Mariman (paralegal)

IRS Issues Revised Phased-in Timeline for FATCA Implementation

Tue, 26 Jul 2011 17:11:53 GMT

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

Wed, 17 Aug 2011 17:58:55 GMT

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 6)

Wed, 28 Sep 2011 11:55:19 GMT

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

District Court Rules in Favor of Government in So-Called FTC Generator Transaction

Fri, 07 Oct 2011 11:19:12 GMT

Seventh Annual Year-End Tax Conference and Celebration

Mon, 10 Oct 2011 14:26:35 GMT

The Dewey & LeBoeuf Tax Department will host its Seventh Annual Year-End Tax Conference and Celebration in New York on December 1. CLE and CPE credits (including ethics credits) will be provided. This event is by invitation only.