Recent Publications



On December 16, 2011, the IRS and the Treasury Department issued comprehensive final transfer pricing regulations related to cost sharing arrangements for the development of intangibles ("CSAs").

Tax Alert


In this article, Tom Zehnle* and Steve Dixon discuss the 2011 Offshore Voluntary Disclosure Initiative, announced by the IRS on February 8.


In this article, Steve Dixon discusses the aftermath of the UBS voluntary disclosure program. The IRS received an unprecedented amount of information about undisclosed offshore accounts in 2009.