Corporations Economic Substance First Shoe Drops for Corporate Inversions By John Harrington and Marc Teitelbaum
OECD Offshore Reporting Tax Conventions and Treaties Automatic Information Exchange: Did the Dog Just Catch the Bus? By John Harrington
Corporations Offshore Reporting IRS Issues PFIC Regulations: A New Start to an Old Beginning By John Harrington and Marc Teitelbaum
Legislation 2014 Will Ring in Uncertainty for Many US Taxpayers By John Harrington and Marc Teitelbaum
Economic Substance Cross-border tax structuring: Is there a common denominator for substance requirements? By John Harrington and Marc Teitelbaum
FATCA Legislation US Treasury Department Releases Latest Round of FATCA Guidance By John Harrington and Marc Teitelbaum
Partnerships/TEFRA Penalties and Reasonable Cause SCOTUS Struggles with TEFRA Jurisdiction: Oral Arguments in United States v. Woods By John Harrington and Marc Teitelbaum
Partnerships/TEFRA Penalties and Reasonable Cause Jurisdiction to Dispute Penalties: Partner v. Partnership-Level Proceedings By John Harrington and Marc Teitelbaum
Penalties and Reasonable Cause Did the Tax Court Enforce Retroactive Penalties? By John Harrington and Marc Teitelbaum
FATCA Offshore Reporting US Government Announces 6-Month Delay in Certain FATCA Rules By John Harrington and Marc Teitelbaum
Individual Taxation IRS Examination Process Litigation Refund Claims The Ninth Circuit Holds Equitable Recoupment Not Time-Barred By Marc Teitelbaum and John Harrington
Penalties and Reasonable Cause Thouron v. United States: Third Circuit Holds Reliance on Counsel may Relieve Penalties for Late Payment of Taxes. By Marc Teitelbaum and John Harrington
Foreign Tax Credits Tax Conventions and Treaties Opportunity to Claim Withholding Tax Overpayment on Dividends Received by Non-EU Investment Funds from Europe By Marc Teitelbaum and John Harrington
IRS Examination Process IRS Summons Tax Conventions and Treaties Can the IRS Circumvent U.S. Law by Issuing a Treaty Request? By Marc Teitelbaum and John Harrington
Partnerships/TEFRA Penalties and Reasonable Cause The Eighth Circuit Weighs in on Whether Outside Basis is an Affected Item at the Partner Level By Marc Teitelbaum and John Harrington
Corporations Offshore Reporting Transfer Pricing Changes Proposed to US Tax Reporting Rules for “Outbound” Transfers By Marc Teitelbaum, John Harrington, and Rich Williams
IRS Examination Process Litigation Tax Crimes “Strategies for Managing Parallel Proceedings with Fifth Amendment Implications,” Inside the Minds: Strategies for Criminal Tax Cases By Marc Teitelbaum and John Harrington
IRS Administration Litigation Qualified Offers and the Recovery of Administrative and Litigation Costs from the IRS By Marc Teitelbaum and John Harrington
