On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the "Act"), commonly known as the "fiscal cliff" legislation.

In a 5-4 decision last week, Justice Thomas joined Justices Ginsburg, Breyer, Sotomayor, and Kagan to hold that two removal statutes, the general removal provision and the removal provision in the Class Action Fairness Act of 2005 ...

On May 17, 2006, President Bush signed into law the Tax Increase Prevention and Reconciliation Act ("TIPRA" or "the Act").

An IRS Office of Chief Counsel memorandum released July 16, 2021 provides a roadmap for IRS transfer pricing examinations involving cost sharing agreements that omit stock-based compensation from the pool of shared IDCs.

The Department of Justice recently announced a landmark settlement agreement with the prominent law firm Skadden, Arps, Slate, Meagher & Flom LLP.

After almost forty years, the IRS has updated the section 482 regulations governing intercompany services (Temp. Reg. § 1.482-9T).

On Wednesday, April 27, 2011, the Supreme Court issued a 5-4 decision in AT&T Mobility v. Concepcion, ruling that the Federal Arbitration Act protects the rights of companies to require arbitration and to preclude individuals from pursuing such arbitration on a classwide basis, even in consumer contracts.

A byproduct of the Bipartisan Budget Act of 2015 is a fundamental change to the rules by which partnerships, and entities that elect to be treated as partnerships for tax purposes, interact with the IRS with respect to the tax examination, litigation, and collection process.

As part of the American Taxpayer Relief Act of 2012, Congress made permanent the portability of estate tax exemption between spouses.

Do the transfer pricing rules apply to your transaction? If you are asking that question because adjusting transfer prices could reduce your tax bill, the answer likely is "yes."

While the rest of us have been distracted by the presidential election, the estate and gift attorneys at the IRS have been steadily issuing guidance and laying out an ambitious plan for more.

This matter arose in the context of a state court action in Fulton County, Georgia, where Marlos L. Chenault and Shayrika L. Chenault (the "Plaintiffs") filed a lawsuit in October 2012 alleging damages...

On Monday, April 25, 2011, the Supreme Court will hear arguments in the Halliburton case,1 a case whose outcome may have a profound impact on future securities fraud class actions filed in the United States. Indeed, the Court may decide whether proof of loss causation prior to merits-based discovery is necessary to certify a securities class action brought under Rule 10b-5, and may also address to what extent a district court may consider, at the class certification stage, evidence that attempts

The court then found that failing to respond to a served summons and complaint constituted such a waiver.

This alert summarizes current law, President-Elect Trump's proposal, and Speaker of the House Paul Ryan's proposal on key individual income tax provisions relevant to high-net-worth individuals.

There are many issues that need to be addressed in public guidance under the expatriation tax provisions of the HEART Act.

On January 31, 2017, the Internal Revenue Service launched its first wave of compliance "campaigns." A campaign is an issue-based compliance process centering on focused examinations, staffed with IRS experts on the targeted subject matter.

Taxpayers with cost sharing arrangements ("CSAs") can again expect close audit scrutiny—and potential adjustments—related to their treatment of stock-based compensation ("SBC") costs.

On December 12, 2019, the Third Circuit issued a decision in In re Odyssey Contracting Corp., finding a debtor-subcontractor had waived its right to appeal from a bankruptcy court's order directing the prime contractor ...

Last month, a federal district court affirmed a bankruptcy court's ruling that an ex-NFL player's potential future recovery from a concussion-related class action settlement agreement was shielded from the reach of creditors ...