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Caplin & Drysdale
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By Todd Phillips, Kevin Maclay, Sally J. Sullivan
On September 22, 2017, the First Circuit Court of Appeals held that § 1109(b) of the Bankruptcy Code (the "Code") provides a creditors' committee with an "unconditional right to intervene" in an adversary proceeding.
By Jonathan Brenner, Elizabeth Stevens
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.
By Beth Kaufman, Amanda M. Leon
For many individuals, it will be advantageous to pay bills for nonbusiness tax preparation and tax advice before the end of 2017.
By Victor Jaramillo, Scott D. Michel, Mark D. Allison
What has been ignored is the tax impact and consequences on the players and their families.
By Caplin & Drysdale
The German newspaper Süddeutsche Zeitung and the International Consortium of Investigative Journalists (ICIJ) followed up the release of the "Panama Papers" in 2016 with what they are referring to as the "Paradise Papers."
By Patricia Gimbel Lewis, J. Clark Armitage, Elizabeth Stevens
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.
By Joanne Youn, Ronald Cluett
Nor does the legal analysis end once a plan has satisfied itself that the church plan exemption properly applies.
By Joanne Youn, Ronald Cluett
The OC List provided on the IRS website identifies changes in qualification requirements effective during a calendar year.
By Christopher Rizek, Charles Ruchelman, Rachel Partain, Arianna Caldwell
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."
By Trevor Potter, Matthew Sanderson, Bryson Morgan
This past weekend, President Donald Trump signed an Executive Order requiring all new appointees in his Administration to sign an ethics pledge that contains special "revolving door" and gift restrictions.
By Mark D. Allison, J. Clark Armitage, Kirsten Burmester, Niles Elber, Neal Kochman, Rachel Partain, Charles Ruchelman, James Salles, Zhanna Ziering, Dustin Barzell
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.
By Jonathan Brenner, Mark D. Allison, Richard Skillman, Kirsten Burmester, Peter Barnes
It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump's proposal and Speaker of the House Paul Ryan's proposal on key corporate tax provisions . . .
By Christopher Rizek, Charles Ruchelman, Arianna Caldwell
On December 23, 2016, the Internal Revenue Service ("IRS") issued Notice 2017-10 identifying certain transactions involving conservation easements as "listed transactions."
By Joanne Youn, Ronald Cluett
In Revenue Procedure 2016-37, the IRS formally announced the elimination, effective January 1, 2017, of the five-year remedial amendment cycle system for individually designed, qualified retirement plans.
By Kirsten Burmester, Scott D. Michel, J. Clark Armitage, Arianna Caldwell
The IRS issued final regulations requiring foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners by obtaining a U.S. "TIN and in many circumstances, filing annual returns.
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