Newsletter
| April 23, 2010
Focus on Tax Controversy and Litigation (Volume III, Issue 2)
In this issue:
- Corporate Directors’ Responsibility for Tax Risk Oversight
- Dewey & LeBoeuf’s Tax Litigation Group Prevents Certification of Proposed Class of BLIPS Tax Shelter Claimants
- Obama Signs Bill Incorporating Economic Substance Doctrine Into the Code
- Department of Justice Submits Brief Opposing Supreme Court Review of the First Circuit’s En Banc Decision in Textron v. United States
- Draft Schedule and Instructions for Reporting Uncertain Tax Positions Released, IRS Commissioner Shulman Discusses Policy Underlying the Reporting Proposal
- United States and Switzerland Sign Protocol to Apply UBS Pact Provisionally, Swiss Parliament’s Upper House Approves Revised Double Taxation Treaty with the United States
- Expedited Guidance on Total Return Swaps Expected
- Treasury Confirms that Proposed Revised OECD Transfer Pricing Guidelines Move Away from Strict Hierarchy of Methods
- IRS Provides Agents with Guidance on Auditing Distressed Asset Trust Tax Shelters
- District Court Holds Severance Payments Exempt from FICA Tax
- Federal Circuit Finds IRS’s Failure to Issue Notices of Deficiency Was Harmless Error
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.
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