Searching Content by Laura Gavioli from McDermott Will & Emery ordered by Published Date Descending.
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Final Section 385 Regulations May Pose Compliance Burdens And Raise Potential Challenges
On November 2, 2016, we participated in a panel discussion at TEI's Houston Global Tax Symposium regarding the effects of the newly-finalized section 385 regulations.
United States
10 Nov 2016
IRS Updates Rules Regarding Appeals Conferences
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016:
United States
26 Sep 2016
Privileged Materials Provided Without Taxpayers' Consent Should Not Waive Privilege
In today's tax environment and with the potential monetary awards to whistleblowers under Internal Revenue Code (Code) Section 7623...
United States
20 Sep 2016
Tax Court Issues Five Discovery Orders Addressing Admissibility Of Expert Reports
On July 13, 14, and 15, 2016, Judge Laro of the US Tax Court (Tax Court) ruled on five taxpayer-filed motions in limine to exclude expert reports in Guidant LLC f.k.a. Guidant Corporation, and Subsidiaries, et al. v. Commissioner.
United States
25 Jul 2016
Tax Court Order Indicates That E-Discovery And Predictive Coding Are Here To Stay
The IRS and the taxpayers had agreed that the taxpayers would run a search for terms determined by the IRS on the potentially relevant documents.
United States
19 Jul 2016
IRS Issues IPU On Corporate Inversions
On June 7, 2016 , the IRS released an LB&I International Practice Unit, providing high-level guidance to IRS field examiners on the application of the anti-inversion rules of Internal Revenue Code section 7874.
United States
7 Jul 2016
Fifth Circuit Rejects Substantial Authority Defense To Penalties
Prudent taxpayers analyze the relevant tax law while structuring and implementing transactions.
United States
1 Jun 2016
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