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  • Article

    Trump Ally Acquitted Of Violating FARA

    A federal jury on November 4 found investor and former Trump associate Thomas Barrack not guilty of criminal charges that included violating the Foreign Agents Registration Act ("FARA") by acting of a foreign agent of the United Arab Emirates.
    United StatesGovernment, Public Sector
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Obtaining Refunds Of Section 6707A And Section 6707 Penalties Paid For Not Properly Reporting Listed Transactions Or Transactions Of Interest (Including Notice 2007-83 And Notice 2016-66)

    On March 3, 2022, in a unanimous opinion authored by its Chief Judge, the U.S. Court of Appeals for the Sixth Circuit invalidated an IRS listing notice on the basis that the agency had not complied...
    United StatesLitigation, Mediation & Arbitration
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    FEC Increases Contribution Limits

    Yesterday, the Federal Election Commission announced updated contribution limits for the 2013-2014 election cycle.
    United StatesStrategy
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Federal Judge Grants IRS "John Doe" Summons Seeking California Gift Tax Records

    A federal district court judge in California has granted the IRS's "John Doe" Summons request seeking to obtain the names and records of California taxpayers who, from 2005 to 2010, transferred property to their children or grandchildren for less than full consideration.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    "Hot Interest" for Large Corporate Underpayments

    "Large corporate under-payments" exceeding $100,000 are subject to a "hot interest" rate that is 2 percent higher than the normal rate for underpayments
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS To Revoke Passports For Seriously Delinquent Tax Debts Starting February 2018

    The IRS intends to issue certifications and decertifications of seriously delinquent tax debts systematically on a weekly basis.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Niles Elber Comments On IRS Shifting Focus To HNW Individuals And Partnerships

    The Internal Revenue Service has made a number of recent moves signaling its resolve to shift its focus to the wealthy and away from working-class taxpayers.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Possible Tax Fallout For Student And Professional Athletes From NCAA-Related Investigations

    What has been ignored is the tax impact and consequences on the players and their families.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Section 6700 – IRS’s Newly Found Weapon Against Professionals

    Recent actions by IRS agents to invoke section 6700 ("Promoting Abusive Tax Shelters, Etc.") portends a new area of concern for professionals who render tax advice.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    September 15th Deadline For Taxpayer Participation In North Carolina Transfer Pricing Resolution Initiative

    On August 1, 2020, North Carolina announced its first formal voluntary disclosure initiative aimed specifically at resolving corporate transfer pricing liabilities.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Switzerland Narrows Advance Notice To Account Holders Of Treaty Requests: Americans With Unreported Accounts Impacted

    Switzerland will now more liberally permit disclosure of bank account information to the U.S. government without advance notice to the account owner.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Treasury Announces Regulations To Address Use Of U.S. LLCs

    In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Cryptocurrency Criminal Tax Cases Coming Soon

    The production of Coinbase client information to the IRS is the result of an IRS "John Doe" summons that was served on Coinbase in 2016.
    United StatesTechnology
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS Releases Draft Instructions For Reporting Health Coverage Information

    The IRS issued draft instructions and sets of FAQs for completing the forms associated with two information reporting requirements under the PPACA.
    United StatesEmployment and HR
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    FARA Back From The Dead: Trump Revives FARA Enforcement

    Shifting Resources in the National Security Division. To free resources to address more pressing priorities, and end risks of further weaponization...
    United StatesInternational Law
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Charitable IRA Rollovers Made Permanent In Recent Extenders Bill

    On December 18, 2015, President Obama signed into law the Protecting Americans from Tax Hikes Act of 2015. The legislation made permanent or extended many of the tax provisions that had previously been extended two years at a time.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    IRS's Offshore Voluntary Disclosure Program Ending: Impact On U.S. Taxpayers

    On March 13, 2018, the Internal Revenue Service (IRS) announced that it will end the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    New Law Changes FBAR Filing Deadline

    Beginning with the FBAR (FinCEN Report 114) for the 2016 year, the filing deadline for the FBAR will be April 15th with a six-month extension until October 15th available upon request.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    Notice 2020-75 Clarifies State & Local Tax Deduction Cap Does Not Apply To Passthrough Entities

    Recently issued Notice 2020-75 provides that Treasury and the IRS intend to issue proposed regulations to clarify the longstanding question of whether the SALT Cap applies to passthrough entities or S-corporations.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered
  • Article

    U.K. Excess Profits Tax Under U.S. Foreign Tax Credit

    Between 1984 and 1996, the government of the United Kingdom, under the control of the Conservative Party, privatized ownership of more than 50 state-owned companies by making public offerings of their stock.
    United StatesTax
    Caplin & Drysdale, Chartered
    Caplin & Drysdale, Chartered

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