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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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Marc Teitelbaum

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Vox Tax: Global Protections for Tax Advice

By Marc Teitelbaum and John Harrington
  • 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

Opportunity to Claim Refund on WHT Overpayment on Dividends Received by Non-EU Investment Funds from Europe – Update

By Marc Teitelbaum
  • Tax Conventions and Treaties

Cross-border exchange of information procedures

By Marc Teitelbaum
  • 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
  • Corporations
  • Economic Substance

First Shoe Drops for Corporate Inversions

By John Harrington and Marc Teitelbaum
  • FATCA

Are You Ready for FATCA?

By John Harrington and Marc Teitelbaum
  • FATCA

US Treasury Releases Substantial FATCA Guidance

By John Harrington and Marc Teitelbaum
  • 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
  • FATCA
  • Offshore Reporting

US Issues Final FATCA Regulations

By John Harrington and Marc Teitelbaum

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