Yesterday, the U.S. Court of Appeals for the Federal Circuit issued a decision in Bechtel National, Inc. v. United States, Docket No.
On July 1, 2019, the Office of the U.S.
In this article, George Hani reviews the background and evolution of the Acknowledgement of Facts (AOF) Inf
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax
Since our last publication, there has been significant activity in some of the most noteworthy government investigations impacting corporate executives. Key developments include:
In this article, George Hani analyzed how the partnership representative role has gr
Last week's Ninth Circuit decision in
On June 18, 2017, the Tax Court issued its opinion in Reserve Mechanical Corp. v. Comm'r, a case involving a microcaptive insurance company.
In this article, Lauren Brig
Just months after passage of the first comprehensive tax reform law enacted in more than 30 years, tax executives are optimistic about the effect of the Tax Cuts & Jobs Act (TCJA) on their busi
In this article, Layla Asali, Andrew Howlett, Katherine Zhang,* and David Zimmerman discuss Revenue Procedure 2017-52, which describes the Internal Revenue Service's (IRS's) pilot program that expa
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