Newsletter
| October 23, 2009
Focus on Tax Controversy and Litigation (Volume II, Issue 8)
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
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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