While student loan bond issuance has declined, qualified bonds are still being issued for certain purposes. A recently issued notice is another in a developing trend of helpful guidance from the IRS, adding some clarity to how student loan authorities ...read more
The amendments to the Federal Rules of Civil Procedure scheduled to take effect Dec. 1 are designed to usher in a new era in the U.S. litigation system, this time acknowledging that what was once known as “e-discovery” is now just discovery. The amendments ...read more
Microsoft Corp. must comply with IRS summonses issued against it in the ongoing transfer pricing audit of the company's 2004-2006 tax years, a district court has held, despite the court's own admission to being "troubled" by the involvement of private firm Quinn Emanuel Urquhart & Sullivan LLP in the audit. In the order granting enforcement of the summonses, filed November 20, the U.S. District Court for the Western District of Washington weighed the testimony of Eli Hoory, senior adviser (transfer pricing operations), IRS Large Business and International Division, against what the court termed the "speculations of Microsoft" and acknowledged the heavy burden the company faced.
View the entire article on LexisNexis® Tax Center
The District of Columbia on November 20 argued in its final brief in an appeal of a trio of transfer pricing suits that it should not be barred from litigating the case after it chose to withdraw its appeal in a similar case against a different taxpayer. The case is a consolidated appeal of three oil industry transfer pricing cases decided by the District's Office of Administrative Hearings (OAH): Hess Corp. v. District of Columbia, Shell Oil Co. v. District of Columbia, and Exxon Mobil Oil Corp. v. District of Columbia.
View the entire article on LexisNexis Tax Center
Global pharmaceutical giant Pfizer Inc. announced November 23 that it will be redomiciling into Ireland in a merger with Dublin-based Allergan PLC that would dwarf all previous inversion deals.
In a joint press release, Pfizer and Allergan announced the $ 160 billion stock deal, whereby the two companies will be combined under Allergan and be renamed Pfizer PLC, with its global operational headquarters in New York and its principal executive offices in Ireland.
The U.S. Tax Court on Monday backed an IRS decision that Kansas-based Fleming Cardiovascular PA's employee stock ownership plan was not qualified for a tax break, as the company failed to make recurring and substantial employer contributions. ...read more
Pfizer's $160 billion bid to acquire Irish drugmaker Allergan will surely attract considerable government attention, but despite its eye-popping size, antitrust issues are unlikely to fell the deal given the way officials look at pharmaceutical mergers ...read more
Pfizer and Allergan tapped seven law firms to help guide their $160 billion merger, drawing on relationships with trusted partners from prior transactions and channeling those firms' experience with megamergers that require a host of attorneys to ...read more
The Pennsylvania Commonwealth Court ruled Monday to refund $3.9 million in corporate net income tax to Nextel Inc., saying a state tax provision that limits deductible losses violated the state’s constitution by financially discriminating against ...read more
A Washington federal court on Monday said Microsoft Corp. has to comply with the Internal Revenue Service’s summonses of several current and former company executives, despite its concerns about the participation of lawyers from Quinn Emanuel Urquhart ...read more
U.S. pharmaceutical giant Pfizer is pushing forward with the largest tax inversion deal ever recorded, spotlighting the meager impact of recent efforts to close loopholes that allow companies to benefit from a lower foreign corporate tax rate as the company ...read more
Canadian oil and gas company Bankers Petroleum Ltd. said Monday that it has won an injunction ordering Albania to unfreeze its local bank accounts and halt enforcement of a $57 million tax assessment, securing an order from the Paris-based International ...read more
Florida Gov. Rick Scott unveiled his proposed $79.3 billion “Florida First” budget Monday, headlined by a goal of $1 billion in tax cuts and $250 million investment in a new Florida Enterprise Fund he says is needed to become the nation's ...read more
In distinguishing between materials prepared by tax professionals in the ordinary course of regulatory compliance and tax analysis tailored toward a specifically anticipated legal challenge — such as IRS scrutiny over a restructuring — the Second Circuit ...read more
A Kentucky man who pled guilty in August to hiding almost $800,000 in a Swiss bank account asked a New York federal judge to sentence him to six months of home confinement instead of prison, saying his crimes were a “once-in-a-lifetime misstep.” ...read more
The U.S. Securities and Exchange Commission has issued two new compliance and disclosure interpretations of the so-called “unbundling rule” as part of the political reaction against inversions. However, the new, separate vote required on material corporate ...read more
U.S. pharmaceutical giant Pfizer said Monday it will combine with Irish drugmaker Allergan in a stock-for-stock deal valued at $160 billion, a deal that comes despite heightened scrutiny of inversion transactions. ...read more
The Internal Revenue Service’s latest move to crack down on so-called inversion transactions will limit some flexibility and curb certain post-closing benefits, but the upcoming rule changes are not enough to put a stop to tax-motivated deal structures ...read more
Deloitte Tax LLP on Wednesday asked a New York state court to dismiss a $500 million suit brought by the estate of the former owner of sports teams including the Detroit Pistons that claimed the firm’s negligence resulted in additional estate and ...read more
The Fifth Circuit affirmed the U.S. Tax Court’s decision to enforce a settlement between a Texas woman and the Internal Revenue Service, ruling Thursday that alleged mistakes made by the woman’s attorney do not justify disturbing the bargain ...read more
The Second Circuit recently ruled that a German auto parts supplier didn’t waive attorney-client privilege by sharing tax advice prepared by Ernst & Young with a consortium of banks, and experts said the decision offers some valuable lessons ...read more
A former Wells Fargo Bank NA subprime loan officer on Friday asked the Second Circuit to revive her whistleblower suit that claims the lender knowingly churned out fraudulent residential mortgage-backed securities and dodged local taxes, saying the bank ...read more
In this week’s Taxation with Representation, two gas suppliers combine forces with help from attorneys from Cleary Gottlieb and Wachtell Lipton, a hotel chain makes a big purchase and a major brewer picks up a craft beer maker. ...read more
Officers of a bankrupt Montana company can be held personally liable for their companies’ unpaid unemployment taxes under a state law, the Ninth Circuit Bankruptcy Appellate Panel has ruled, finding that the taxes are entitled to priority status ...read more
The Pennsylvania Superior Court on Thursday upheld a decision finding that a Babst Calland Clements & Zomnir PC attorney had not committed malpractice after failing to prevent a tax sale from moving forward on a commercial property held under mortgage ...read more