Last month a unanimous Ninth Circuit affirmed the Tax Court thereby preserving Amazon’s victory in a major transfer pricing dispute. The decision is also a victory for taxpayers generally because of the Ninth Circuit’s...more
In a release dated September 4, 2018, the IRS reminded taxpayers that the program that allowed for reduced civil liabilities for offshore reporting violations is coming to an end on September 28. The program, generally known...more
On August 7, 2018, the Ninth Circuit panel vacated its earlier opinion in Altera v. Commissioner that, in a nutshell, had concluded that Treasury had complied with the Administrative Procedure Act (the “APA”) in issuing final...more
On November 29, 2017, the U.S. District Court for the Northern District of California dealt a partial blow to the U.S. Department of Justice and the IRS in connection with their collective efforts to enforce an expansive and...more