The New Mexico Court of Appeals held that for purposes of imposing the state's gross receipts tax, Barnes & Noble Booksellers, Inc.'s (Booksellers) in-state activities may be imputed to an out-of-state retailer (Taxpayer) based on the use... Read More
By Bill Pauls and Michael Miles, Sutherland Asbill & Brennan LLP On July 30, 2012, the IRS Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions... Read More
By Robb Chase, Reggie Clark, Jeff Mace, Michael Miles, Carol Tello, Karl Zeswitz, Saren Goldner, and Bill Pauls, Sutherland Asbill & Brennan LLP On June 7, 2012, Treasury and the Internal Revenue Service (the IRS) issued much-anticipated final... Read More
By Tom Cullinan , Joe DePew , and Shane Lord , Sutherland Asbill & Brennan LLP We rarely send out Legal Alerts about the so-called "TEFRA" rules that govern partnership audits and litigation because so few people would read them. In... Read More
By Robb Chase and Amanda Pugh On February 14, 2012, the Department of Treasury's Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial... Read More