Newsletter
| March 25, 2010
Focus on Tax Controversy and Litigation (Volume III, Issue 1)
In this issue:
- President Signs HIRE Act Including Provisions of Foreign Account Tax Compliance Act
- Ninth Circuit Reverses Its Prior Xilinx Opinion, Affirms Tax Court
- IRS Chief Counsel Wilkins Discusses Issues Related to Announcement 2010-9, Reporting of Uncertain Tax Positions
- An Overview of Developments In Reporting Obligations Applicable to Foreign Accounts and a Review of Recently Proposed FBAR Regulations
- Tax Court Holds that Outbound Guarantee Fees Are Not Subject to Withholding
- Federal Circuit Vacates and Remands Penalty Portions of Jade Trading Decision
- Senate Passes Bill Incorporating Economic Substance Doctrine Into the Code
- IRS and SEC Announce Memorandum of Understanding for Tax Exempt Bonds
- Swiss Government to Seek Parliamentary Approval of UBS Pact, German State Receives Secret Account Data
- District Court Rules that Lawyer’s Disclosure of Alleged Tax Evasion to IRS Did Not Violate Attorney-Client Privilege
- Bankruptcy Judge Accepts Madoff Trustee’s Use of the “Net Investment Method;” Tax Treatment of Investor Losses Is Unaffected
- IRS Further Extends Moratorium on Enforcement Actions Relating to Tax Shelter Penalties Under Section 6707A
- In Memoriam
For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:
This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent.
For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383