Newsletter
| June 24, 2010
Focus on Tax Controversy and Litigation (Volume III, Issue 4)
In This Issue:
- Multilateral Tax Cooperation Gets a Boost: The United States and Fourteen Countries Revise the OECD-Council of Europe Treaty
- IRS Officials Discuss "Foreign Financial Institution" Classification Under FATCA, Multinational Framework for Information Reporting
- IRS Updates LMSB Examination Procedures, Unveils Quality Examination Process
- Tax Court Declines to Follow Overstatement of Basis Regulations Under Section 6501(e)(1)(A)
- IRS Issues Guidance Providing that a Material Advisor's Status Is Not Contingent on Timing of Fees
- IRS Releases Procedures for Whistleblower Paydays
- IRS Still Evaluating Audit Approach with Respect to Build America Bonds
- U.S. District Court Rules that Taxpayer Is Not Entitled to Overpayment Interest on Amounts Paid as a Deposit in the Nature of a Cash Bond
- Swiss Parliament Approves UBS Pact
- Tax Court Mandates Electronic Filing for Most Parties
- Changes to Tiered Issue Process Likely, IRS Official Says
- IRS Official Warns Government Will Challenge Claims of Privilege Asserted by Accountants
- Dewey & LeBoeuf's Client Coalition Submits Comment Letter on Schedule UTP
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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