Newsletter
| January 31, 2012
Focus on Tax Controversy and Litigation (Volume IV, Issue 11)
In this issue:
- New Temporary and Proposed Regulations Affect Taxation of US Equity Derivatives
- Vodafone Wins High-Profile Indian Tax Case
- Court of Federal Claims Holds Privilege Waived with Respect to Penalty-Defense Documents
- Tenth Circuit Affirms Tax Court in Anschutz, Finds Variable Prepaid Forward Contracts Combined With Share Lending Agreements Resulted in Closed Sale of Stock
- Appellate Court Reverses Trial Court in Castle Harbour, Holds Banks Do Not Qualify as Partners and Imposes Substantial Understatement Penalty
- Tax Court Proposes Rule Changes
- IRS Reopens Offshore Voluntary Disclosure Program
- Swiss Parliament Postpones Vote on Ratification of Amended Tax Treaty
- FinCEN Clarifies FBAR Rules for Former Employees
- Three Swiss Bankers Indicted for Allegedly Conspiring to Conceal US Taxpayer Accounts from the IRS
- Tax Court Applies Economic Substance Doctrine to So-Called “OPIS” Transaction, Upholds Accuracy-Related Penalties
- Tax Court Rules that Certain Subpart F Inclusions Are Not Dividends
- IRS Updates Guidance Related to Accuracy-Related Penalties
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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