Newsletter
| January 27, 2010
Focus on Tax Controversy and Litigation (Volume II, Issue 11)
In this issue:
- So Much for Restraint
- Swiss Court Prevents Disclosure of Some UBS Data to the US; Same Court Earlier Found FINMA Exceeded Authority by Releasing Names of UBS Clients
- IRS Tax Exempt Bond Office Increasing Enforcement Efforts
- New Total Return Swap Audit Guidelines Reveal Scope of IRS Query
- DOJ Issues Guidance Regarding Criminal Discovery Practices
- UBS Issues Code of Business Conduct and Ethics
- Wells Fargo Denied $115 Million Refund in SILO Case
- Textron Appeals First Circuit’s Decision to Supreme Court
- Tax Court Rules on Listed Transactions
- IRS Prevails in Tax Court and Secures 40 Percent Accuracy-Related Penalty Where Taxpayer’s Partnership Transaction Involved Offsetting Market-Linked Deposit Contracts
- Veritas Software Corp., et al. v. Commissioner: IRS Suffers Billion-Dollar Tax Court Loss in Transfer Pricing Dispute
- Supreme Court Requests Solicitor General Input on Retroactive Tax Collection
- Tax Lawyer Pleads Guilty to Attempting to Evade Tax
- Update on Enforcement Actions Relating to Section 6707A
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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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