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 ...

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.

Over the past few years, the political law landscape has changed dramatically for those engaging in political activities, including for-profit corporations and nonprofit entities.

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.

Another election season is upon us and with it a flurry of information — and misinformation — about what churches and other religious organizations can and cannot do. Fortunately for religious leaders, the law is relatively clear.

Second, independent of the resource issue above, at least so far, IRS seems to have failed to reap huge enforcement, compliance, and revenue producing gains within their grasp based on the effective exploitation of the initial investigative breaks and international negotiations with the Swiss government.

Civil examinations and litigations and criminal cases often involve multiple, sometimes related, persons each of whom might be represented by separate counsel.

To protect APA benefits, taxpayers should make a good faith effort to present known facts during the APA process, to comply with the APA, and to correct any non-compliance when discovered.

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

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...

For 300 years, the principle known as "the revenue rule" sharply limited collaboration among nations with respect to tax. In the seminal 1729 court decision of Attorney General v. Lutwydge...

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.

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...

In 2016, Lamps Plus was the victim of a phishing attack, which resulted in the improper dissemination of employee data.

Two recent judicial decisions addressing the so-called "global netting" of interest in tax cases potentially offer corporate taxpayers new opportunities.

The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.

The Editor interviews Patricia Gimbel Lewis, Member of Caplin & Drysdale, Chartered’s Washington, DC office.

On March 27, the Coronavirus Aid, Relief, and Economic Security ("CARES") Act was signed into law.

On June 17, 2014, a three-judge panel of the Third Circuit Court of Appeals vacated a District Court’s dismissal order and resuscitated a bankruptcy appeal.