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  • Article

    Abusive Small Captive Insurance Companies Added To IRS "Dirty Dozen Tax Scams"

    For the first time, the Internal Revenue Service (IRS) has included certain small captive insurance companies (CICs) in its annual list of "Dirty Dozen Tax Scams."
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Americans With Israeli Bank Accounts: Voluntary Disclosures To IRS Becoming A Necessity

    On February 14, 2013, court filings revealed that an American citizen pled guilty to crimes involving failures to report the existence of two bank accounts maintained in Israel and the income from those accounts to the Internal Revenue Service.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Challenge To The Constitutionality Of The ACA Raises NII Tax Refund Possibility

    The constitutionality of the Affordable Care Act (ACA) is being challenged before the Supreme Court for a third time this fall in the case of California v. Texas...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    D.C. Repeals Tax On Municipal Bond Interest For Individuals

    On July 30, 2013, the District of Columbia retroactively repealed the provision that would have subjected most tax-exempt bonds owned by D.C. residents to D.C. income tax.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS To Hire 700 For Civil And Criminal Tax Enforcement

    On May 3, the Internal Revenue Service announced that it will be hiring between 600 and 700 new federal tax enforcement personnel.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Taxpayer Defeats IRS Penalty In Tax Court For Conservation Easement Transaction

    On November 20, 2021, the Tax Court ruled in favor of our client facing penalties related to disallowed charitable contribution deductions for conservation easements.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    The Foreign Account Tax Compliance Act and Notice 2010-60

    On March 18, 2010, the Foreign Account Tax Compliance Act ("FATCA"), Subtitle A of Title V of Public Law 111-147, was enacted into law. The provisions of FATCA are intended, as the title indicates, to promote compliance with U.S. law requiring U.S. persons to report income from offshore accounts.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    CTA Remains Applicable To Foreign Reporting Companies And Their Foreign Beneficial Owners

    Last Friday, the Treasury Department's Financial Crimes Enforcement Network ("FinCEN") published interim final rules substantially narrowing beneficial ownership information ("BOI") reporting obligations under the Corporate Transparency Act ("CTA").
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS "Dirty Dozen" List Includes "Potentially" Abusive Use Of U.S.-Malta Tax Treaty In Pension Plans

    The Internal Revenue Service (IRS) has placed certain Malta-based pension plan arrangements on its annual "Dirty Dozen" list of "tax scams."
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Captive Insurance Industry Should Be Aware Of State Reporting Obligations For Transactions Of Interest

    On November 1, 2016, the Internal Revenue Service ("IRS") issued Notice 2016-66, identifying certain transactions relating to "micro-captive" insurance companies as "transactions of interest."
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Ready Or Not, It's Time For Transparency FinCEN Proposes Rules To Implement Beneficial Ownership Reporting Requirements

    Proposed regulations promulgated on December 8, 2021 by the Financial Crimes Enforcement Network ("FinCEN"), a bureau of the Department of the Treasury, bring the beneficial ownership reporting rules of the Corporate Transparency Act1 (the "CTA") one step closer to life.
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Update On Nonprofit Donor Disclosure Requirements

    Earlier this week, in Bullock v. Internal Revenue Service, a U.S. District Court—at least temporarily--reinstated the donor disclosure requirement that the IRS eliminated for many 501(c) organizations last year.
    United StatesCorporate/Commercial Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Congressman Henry Cuellar, Democrat Of Texas, Charged With Bribery And Violations Of Foreign Agents Registration Act

    Earlier this month, an indictment was unsealed in the Southern District of Texas charging Congressman Henry Cuellar and his wife, Imelda, with participating in schemes involving bribery...
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Is The Bondi Memorandum Dead? Trump Executive Order Unpauses FARA Enforcement

    In February 2025, U.S. Attorney General Pamela Bondi issued a wide-ranging formal Memorandum that appeared to pause most FARA enforcement actions.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    D.C. Circuit's First Farhy Opinion Requires Reconsideration

    Jonathan Black authored the article "D.C. Circuit's First Farhy Opinion Requires Reconsideration" published in Tax Notes on May 21, 2024.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Issues First Partnership Audit Regulations

    On August 4, 2016, the Treasury Department issued its first temporary regulations under the new partnership audit and collection regime found in the Bipartisan Budget Act of 2015.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Peter Barnes Comments On Pillar 2 Signing Deadline Delayed

    Countries agreed to push back a deadline to sign a multilateral treaty that's part of the international tax pact until mid-2024...
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    U.S. Passports In Jeopardy For Taxpayers Owing The IRS

    On December 4, the United States dramatically increased the consequences of tax non-compliance when President Obama signed into law the Fixing America's Surface Transportation Act (the "FAST Act").
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Crypto Form 8300 Filing Delay

    The regulatory framework surrounding cryptocurrencies continues to take shape. Earlier this week, Treasury and the IRS issued Announcement 2024-4...
    United StatesTechnology
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    New Cryptocurrency Guidance

    In Revenue Ruling 2019-24, the IRS analyzes the tax ramifications of "hard forks" in cryptocurrencies.
    United StatesTechnology
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered

Showing 21–40 of 412 results

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