News & Analysis as of

U.S. Treasury Tax Litigation

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

Vinson & Elkins LLP on

In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more

McDermott Will & Schulte

Tax Court Rules Limited Partners May Be Subject to Self-Employment Tax

On November 28, 2023, the US Tax Court granted partial summary judgment in favor of the Internal Revenue Service (IRS) in Soroban Capital Partners LP v. Commissioner and held that “limited partners” are defined...more

McDermott Will & Schulte

Weekly IRS Roundup March 13 – March 17, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

McDermott Will & Schulte

Tax Court Posts New Citation and Style Manual

A substantial amount of our practice over the years has involved representing clients before the US Tax Court. And, we both started our tax careers clerking at the Tax Court and working on dozens of orders and opinions....more

McDermott Will & Schulte

IRS Chief Counsel Signals Increased Tax Enforcement

The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws....more

McDermott Will & Schulte

Weekly IRS Roundup September 16 – 20, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more

Morrison & Foerster LLP

No (Tax) Man Is Above the Law: The Tax Court Rejects Final Cost-Sharing Regulations in Altera Corporation and Subsidiaries v....

Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more

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