The Bipartisan Budget Act of 2015 fundamentally changed the rules by which partnerships, and entities taxed as partnerships (such as limited liability companies), interact with the Internal Revenue Service in an audit or litigation.

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.

In some recent transfer pricing audits, the Internal Revenue Service (IRS) "flipped the tested party" after examining transactions between related U.S. and foreign companies.

On February 24, 2022, the IRS issued proposed regulations (the "Proposed Regulations") for determining the required minimum distribution ("RMD") payable to retirement plan participants and their beneficiaries.

In a reviewed opinion, Valley Park Ranch,[1] the Tax Court thoughtfully reconsidered its position on the validity of the so-called "proceeds regulation", Treas. Reg. § 1.170A-14(g)(6)(ii)...

In this client alert, we discuss some considerations for employers in light of recent IRS initiatives concerning the Employee Retention Credit ("ERC").

On July 17, 2015, the Internal Revenue Service released three new "practice units," each examining a particular type of transaction involving a controlled foreign corporation.

The U.S. Supreme Court recently granted certiorari in Moore v. United States, a case involving a constitutional challenge to section 965 of the Internal Revenue Code.

In 2004, Congress provided the IRS with powerful tools to regulate the perceived proliferation of abusive tax shelters. One of those tools, section 6707A of the Internal Revenue Code, imposes a significant penalty on taxpayers who fail to disclose a "reportable" transaction to the IRS.

It may be time to take a fresh look at the Limitation on Benefits article in U.S. income tax treaties.

On Monday, June 6, 2011, the Supreme Court issued a unanimous decision in Erica P. John Fund, Inc. v. Halliburton Co., ruling that plaintiffs in a private securities fraud class action need not prove loss causation in order to obtain a certified class.

Effective January 1, 2017, the Office of Government Ethics (OGE) is revising the gift rules applicable to executive branch employees.

The crisis in the financial sector has put pressure on both legislatures and courts to increase protections for investors.

There can be little doubt that the amount sought by the United States in its civil action constitutes a "deficiency" within the meaning of section 6211...

On Wednesday January 26, 2011, federal prosecutors in Newark, New Jersey indicted Mr. Vaibhav Dahake on charges of conspiracy to defraud the United States by concealing bank accounts in India and the British Virgins Island.

On September 16, 2014, the Organization for Economic Cooperation and Development released its 2014 deliverables on the Base Erosion and Profit-Shifting project.

On May 20, 2015, the Treasury Department released five proposed changes to the U.S. Model Income Tax Treaty (the U.S. Model).

In a decision rendered on June 6, 2022, Justice Sotomayor authored the Supreme Court's unanimous decision in the case Siegel v. Fitzgerald, holding that a statutory increase in United States...

Michael Cohen's testimony on February 27, 2018 before the U.S. House Committee on Oversight and Reform featured several heated exchanges, including one particular line of questioning about the Foreign Agents Registration Act ...

Under broad regulatory authority contained in section 6039G, the 2009 Notice expands the reporting that is due from covered expatriates in years following the year of expatriation.