Tahmidur Remura Dewey LeBoeuf – Tax Controversy and Litigation

First Circuit Affirms that Tax Accrual Workpapers are Entitled to Work Product Protection

Thu, 18 Jun 2009 16:29:34 GMT

January 22, 2009

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 Settlement Initiatives for Taxpayers who Engaged in LILO or SILO Transactions

Thu, 18 Jun 2009 16:29:36 GMT

August 7, 2008

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

Wed, 29 Jul 2009 18:10:21 GMT

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

Wed, 29 Jul 2009 18:21:54 GMT

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

Wed, 29 Jul 2009 18:22:42 GMT

This second issue of Focus on Tax Controversy and Litigation features articles by Sam Riesenberg, Dawn M. Rhea, Cathy Fung, Rachel L. Partain, Jennifer O’Brien, Alexandra Minkovich, Zhanna A. Ziering and Richard A. Nessler.

Focus on Tax Controversy and Litigation (Volume I, Issue 10)

Wed, 29 Jul 2009 18:25:41 GMT

This is the tenth issue of Focus on Tax Controversy and Litigation. It features articles by Zhanna Z. Ziering, Brittany L. Harrison, Tamara W. Ashford, William E. Kellogg, Amitai B. Barth, Cathy Fung, Jennifer M. O’Brien, Richard A. Nessler, Taylor A. Romigh, Eric C. Miller, Meghan A. Brown and Matthew C. Oxman.

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

Fri, 31 Jul 2009 12:29:22 GMT

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

Fri, 07 Aug 2009 12:11:17 GMT

This is the fourth issue of Focus on Tax Controversy and Litigation. It features articles by Kelly Librera, Richard A. Nessler, Alexandra Minkovich, Eric C. Miller, Afua Annor, Dominic Valerian, Rachel L. Partain, Cathy Fung, Gabriella McDonald, Erica Howard-Potter, Zhanna Ziering and Jennifer O’Brien.

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

Fri, 07 Aug 2009 12:14:36 GMT

This is the fifth issue of Focus on Tax Controversy and Litigation. It features articles by Alexandra Minkovich, Brittany L. Harrison, Richard A. Nessler, Alexander Roberts, Dawn M. Rhea, Amy Duvall, Eric Cheung, Jaclyn Link and Jennifer O’Brien.

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

Fri, 07 Aug 2009 12:41:49 GMT

This is the third issue of Focus on Tax Controversy and Litigation. It features articles by Artyom Linnik, Seth Farber, Mark Noferi, Jennifer O’Brien, Matthew Oxman, Dawn Rhea, Rachel Partain, Eric Miller, Danielle Sugarman, Alexandra Minkovich, Sam Riesenberg, Zhanna Ziering, Cathy Fung, Amy Anderson and Bonnie Diaz.

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

Fri, 07 Aug 2009 12:49:38 GMT

This is the eighth issue of Focus on Tax Controversy and Litigation. It features articles by Alexandra Minkovich, Rachel L. Partain, Brittany L. Harrison, Richard A. Nessler, Cathy Fung, Zhanna Ziering, Eric C. Miller, and Jennifer O’Brien.

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

Fri, 07 Aug 2009 12:53:15 GMT

This introductory issue of Focus on Tax Controversy and Litigation, a monthly newsletter, features articles by Jennifer M. O’Brien, Alexandra Minkovich and Zhanna A. Ziering.

Focus on Tax Controversy and Litigation (Volume I, Issue 12)

Fri, 07 Aug 2009 13:00:06 GMT

This is the twelfth issue of Focus on Tax Controversy and Litigation. It features articles by Amitai B. Barth, Tamara W. Ashford, Taylor A. Romigh, Alexandra Minkovich, Sam Riesenberg, Kenneth Barr, Cathy Fung, Rachel L. Partain, Lauren Aronson, William E. Kellogg, Richard A. Nessler and Jennifer M. O’Brien.

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

Fri, 07 Aug 2009 13:02:39 GMT

This is the seventh issue of Focus on Tax Controversy and Litigation. It features articles by Brittany L. Harrison, Alexandra Minkovich, Dawn M. Rhea, Rachel L. Partain, Graham Green, Cathy Fung, Stephen A. Best, C. Clark, Timothy J. Coleman, Michael R. Hoernlein, Jennifer O’Brien, Eric C. Miller, Zhanna Ziering, and Richard A. Nessler.

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

Fri, 07 Aug 2009 13:05:46 GMT

This is the sixth issue of Focus on Tax Controversy and Litigation. It features articles by Lawrence M. Hill, Rachel L. Partain, Richard A. Nessler, Cathy Fung, Eric C. Miller, Alexandra Minkovich, and Jennifer O’Brien.

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

Fri, 07 Aug 2009 15:32:23 GMT

This is the ninth issue of Focus on Tax Controversy and Litigation. It features articles by Larry Hill, Alexandra Minkovich, Richard A. Nessler, Brittany L. Harrison, Zhanna Ziering, Amitai Barth, Tamara Ashford, Rachel L. Partain, A. Ferris, Jennifer O’Brien, Taylor Romigh, Matthew Oxman, Meghan Brown, and William Kellogg.

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

Treasury Department and IRS Announce Final Regulations for Reportable Transactions

Mon, 19 Oct 2009 15:47:57 GMT

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

Tue, 20 Oct 2009 12:08:51 GMT

In this issue:

Details of the UBS-IRS Settlement Released
Current Developments Related to the US Government’s Focus on Offshore Tax Evasion
IRS Issues Revenue Ruling on Risk Distribution in the Reinsurance Context
Pierre v. Commissioner: A Single-Member LLC Is Not Disregarded for Gift Tax Purposes
Recent Cases Involving the Extended Limitations Period for Substantial Omissions of Gross Income
Aloe Vera of America, Inc. v. United States: Ninth Circuit Vacates and Remands Case on Improper Disclosures Made Under the US-Japan Tax Treaty
Tax Court Rules that Res Judicata Does Not Prohibit the IRS From Recapturing an NOL Refund Even Though the Tax Years at Issue Had Already Been Litigated
Tax Court Denies Motion to Compel Disclosure of Tax Opinions Collected by IRS
Court Denies Refund Related to Repatriation of Offshore Earnings
Dewey & LeBoeuf Congratulates NYU LL.M. in Taxation Graduates

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

Tue, 20 Oct 2009 12:32:15 GMT

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

Fri, 13 Nov 2009 15:07:49 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 6)

Tue, 17 Nov 2009 12:32:57 GMT

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

Focus on Tax Controversy and Litigation (Volume II, Issue 10)

Thu, 24 Dec 2009 12:48:22 GMT

In this issue:

Dewey & LeBoeuf Holds Fifth Annual Year‑End Tax Conference and Celebration
New Trend: Government Requesting Jury Trials in Tax Cases
DOJ Seeking Identities of Stanford Group’s US Investors
Global Crackdown on Tax Evasion
Details of Criteria Used to Identify Individuals to Be Turned Over to the US Government in UBS Litigation; United States Looking to Conduct Joint Audits with Treaty Partners
IRS Commissioner Shulman Speaks on the Role of Corporate Boards of Directors with Respect to Overseeing Tax Risk
IRS Explains Strategy to Improve Withholding Tax Compliance
Lawmakers Seek to Modify Tax Shelter Penalties Created in 2004
District Court Finds Partnership Contribution Constituted a Disguised Sale but Statute of Limitations Barred Assessment
Current Status of Docketed Foreign Tax Credit Cases
General Electric Capital Canada, Inc. v. The Queen
District Court Grants Government’s Motion to Dismiss in Refund Case
Fifth Circuit Affirms Decision Upholding the Disallowance of a “Midco” Tax Shelter Transaction
IRS Coordinates Its Position Regarding Six-Year Statute of Limitations Regulations
Overview of the Treasury Department’s 2009-2010 Priority Guidance Plan

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

Focus on Tax Controversy and Litigation (Volume II, Issue 12)

Fri, 26 Feb 2010 10:48:13 GMT

Taxpayer Wins LILO Case in the Court of Federal Claims

Wed, 07 Apr 2010 11:46:20 GMT

Corporate Directors’ Responsibility for Tax Risk Oversight

Thu, 08 Apr 2010 16:40:16 GMT

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

Fri, 16 Apr 2010 14:52:12 GMT

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

Fri, 23 Apr 2010 17:47:44 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

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

Thu, 29 Jul 2010 12:47:35 GMT

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

Fri, 27 Aug 2010 11:27:15 GMT

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

Fri, 03 Sep 2010 15:11:17 GMT

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

Fri, 15 Oct 2010 17:46:48 GMT

In this issue:

IRS Releases Final Schedule UTP and Accompanying Instructions
FATCA Update: IRS Issues Much-Awaited Guidance on FATCA Implementation for Priority Issues, Seeks More Public Input
IRS Issues Guidance on Codified Economic Substance Doctrine
Tax Court Finds Taxpayer Not Liable as Transferee in MIDCO Transaction Case
Buyer Beware: Decision of Bombay High Court Could Have Significant Impact on M&A Transactions with Connections to India
Ninth Circuit Affirms Dismissal of Action Brought to Compel Disclosure of Documents the IRS Shared with the Russian Tax Authorities
District Court Strikes Down Government’s Attempt to Seek FBAR Penalties
Bankruptcy Plan Dismissed When Sole Purpose Was Tax Avoidance
Swiss Government Adopts New Regulation in Connection with New and Amended Double Taxation Agreements, Faces Lawsuit Over Information Disclosed to the United States
Treasury Issues Proposed Regulations for Series LLCs and Cell Companies
New IRS Procedures Allow Pre-Payment Appeals Review of International Penalties
Proper Use of Private Letter Rulings: Amergen Energy Co. v. United States
IRS Officials Discuss New PFIC Method for Voluntary Disclosure Participants, Focus on International Enforcement
Institute of International Bankers Submits Comments to IRS on Reporting of Uncertain Tax Positions

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

Fri, 29 Oct 2010 16:02:45 GMT

IRS Releases Final Schedule UTP and Accompanying Instructions

Wed, 10 Nov 2010 14:13:39 GMT

The War on Tax Fraud and the War in Afghanistan: Is there a Link?

Wed, 10 Nov 2010 14:17:44 GMT

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

Wed, 24 Nov 2010 13:06:39 GMT

Focus on Tax Controversy and Litigation (Volume III, Issue 10)

Mon, 31 Jan 2011 12:57:22 GMT

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

Mon, 07 Feb 2011 15:23:14 GMT

Focus on Tax Controversy and Litigation (Volume III, Issue 12)

Mon, 28 Feb 2011 17:18:58 GMT

In this issue:

IRS Announces Second Voluntary Disclosure Program
IRS Officials Comment on OPR, FATCA, and the Supreme Court’s Mayo Decision
Fourth and Fifth Circuits Weigh in Against Application of the Six-Year Statute of Limitations for Cases Involving an Overstatement of Basis
Tax Court Applies Pre-Regulation Continuity of Interest Doctrine to Determine that Bankruptcy Transaction Lacked Continuity of Interest Under Section 368(a)
Swiss Government Announces Plan to Relax Provisions Related to Exchange of Information in Tax Matters
Four Swiss Bankers Indicted for Conspiracy to Defraud the United States
US Seeks Civil Injunction Against California Lawyers and Kentucky Financial Professional to Bar Them FromPromoting "Intermediary Transaction" Tax Shelter
Tax Court Determines It Has Jurisdiction Over Interest-Netting Claims and Rejects IRS’s Longstanding Interpretation Regarding Retroactive Application of an Uncodified Special Interest Netting Rule

IRS Releases “Frequently Asked Questions” on Schedule UTP

Wed, 23 Mar 2011 19:34:56 GMT

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

Wed, 13 Apr 2011 17:07:39 GMT

In this issue:

2 IRS Releases “Frequently Asked Questions” on Schedule UTP
4 Fourth Circuit Reverses Tax Court in Virginia Historic Tax Credit Fund 2001 LP
6 IRS Releases Revised FBAR Form to Reflect Final Regulations; Notice Issued to Provide Additional Guidance
8 Invoking Mayo, the Federal Circuit Defers to Retroactive Treasury Regulations in Applying Extended Statute of Limitations to a Case Involving an Overstatement of Basis
10 Tax Court Finds Taxpayers Not Liable As Transferees in Two MIDCO Transaction Cases
16 Tax Court Disallows Losses From CARDS Transaction, Imposes Accuracy-Related Penalty
19 Criminal Complaint Filed Against Former Swiss Banker

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

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

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

Mon, 31 Oct 2011 15:49:37 GMT

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

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

Tue, 01 Nov 2011 09:15:48 GMT

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

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

Wed, 30 Nov 2011 16:38:52 GMT

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

Focus on Tax Controversy and Litigation (Volume IV, Issue 10)

Tue, 03 Jan 2012 10:18:06 GMT

In this issue:

IRS Issues Temporary and Proposed Regulations on Foreign Financial Asset Reporting and Releases Guidance on FBAR Rules for US Citizens and Dual Citizens Residing Outside the US
Taxpayer Files Supreme Court Brief in Home Concrete & Supply Company, Argues Overstatement of Basis Should Not Extend Statute of Limitations for Assessment
Swiss Council of States Approves Expansion of the Cross-Border Information Disclosure Provisions of the US-Swiss Double Taxation Treaty
Joint Congressional Hearing Held on the Taxation of Financial Instruments
Final Regulations Issued on Tax Return Preparer Penalties under Section 6695
Number of Items Listed on Schedule UTP Lower Than Expected
Federal Judge Permits “John Doe” Summonses to Be Issued to California’s Board of Equalization
IRS Issues Final Regulations on Conduit Financing
Seventh Annual Year-End Tax Conference

New Temporary and Proposed Regulations Affect Taxation of US Equity Derivatives

Thu, 26 Jan 2012 09:32:00 GMT