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02.01.2007

External Publication

IRS Provides New Cross-Licensing Guidance

01.28.2007

External Publication

Business Judgment Test for Services: Judgment or Process?

01.17.2007

Firm Publication

IRS Issues Guidance on Temporary CFC Look-Through Rule

International Tax Alert

01.12.2007

Firm Publication

IRS Liberalizes Subpart F Rules

International Tax Alert

01.08.2007

External Publication

Words of Wisdom for the 110th Congress

12.22.2006

Firm Publication

IRS Delays Effective Date and Clarifies Transfer Pricing Regulations for Services Transactions

International Tax Alert

12.02.2006

External Publication

Transfer Pricing for Services Under the 1968 Treasury Regulations and the 2006 Temporary Treasury Regulations

11.22.2006

Firm Publication

State Tax Alert: West Virginia Supreme Court Holds Physical- Presence Principle Inapplicable for Franchise and Income Tax Purposes

Tax Controversy Alert

10.20.2006

Firm Publication

State Tax Alert: New Jersey Supreme Court Holds Physical Presence Principle Inapplicable for Corporation Business Tax Purposes

Tax Controversy Alert

09.13.2006

Firm Publication

IRS and Glaxo Announce Settlement of Transfer Pricing Dispute

Tax Controversy Alert

08.18.2006

Firm Publication

IRS Issues Temporary Regulations on Interest Expense Allocation for Foreign Corporations

International Tax Alert

08.04.2006

Firm Publication

IRS Issues Proposed Foreign Tax Credit Regulations on “Legal Liability” for Foreign Taxes

International Tax Alert

08.03.2006

Firm Publication

IRS Issues Transfer Pricing Regulations For Services Transactions

International Tax Alert

08.01.2006

Firm Publication

Fifth Circuit Reverses Tax Court’s Valuation in Conversion of Exempt Organization

Tax Controversy Alert

07.12.2006

Firm Publication

Federal Circuit Reverses Trial Court in Coltec v. United States

Tax Controversy Alert

07.06.2006

Firm Publication

Everson Testifies on Compliance Priorities

Tax Controversy Alert

05.30.2006

Firm Publication

Simpler but Not Simple: Treasury Issues Final and Temporary Section 199 Regulations

Tax and Employee Benefits Alert

03.20.2006

Firm Publication

Treasury Solicits Input On Taxation of Cross-Licensing Arrangements

International Tax Alert

03.10.2006

External Publication

Application of U.S. Treaties to Hybrid Entities

02.08.2006

Firm Publication

Amtrak Prevails in Refund Suit Involving the Federal Communications Excise Tax

Tax Controversy Alert

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publications

IRS Provides New Cross-Licensing Guidance

Business Judgment Test for Services: Judgment or Process?

IRS Issues Guidance on Temporary CFC Look-Through Rule

IRS Liberalizes Subpart F Rules

Words of Wisdom for the 110th Congress

IRS Delays Effective Date and Clarifies Transfer Pricing Regulations for Services Transactions

Transfer Pricing for Services Under the 1968 Treasury Regulations and the 2006 Temporary Treasury Regulations

State Tax Alert: West Virginia Supreme Court Holds Physical- Presence Principle Inapplicable for Franchise and Income Tax Purposes

State Tax Alert: New Jersey Supreme Court Holds Physical Presence Principle Inapplicable for Corporation Business Tax Purposes

IRS and Glaxo Announce Settlement of Transfer Pricing Dispute

IRS Issues Temporary Regulations on Interest Expense Allocation for Foreign Corporations

IRS Issues Proposed Foreign Tax Credit Regulations on “Legal Liability” for Foreign Taxes

IRS Issues Transfer Pricing Regulations For Services Transactions

Fifth Circuit Reverses Tax Court’s Valuation in Conversion of Exempt Organization

Federal Circuit Reverses Trial Court in Coltec v. United States

Everson Testifies on Compliance Priorities

Simpler but Not Simple: Treasury Issues Final and Temporary Section 199 Regulations

Treasury Solicits Input On Taxation of Cross-Licensing Arrangements

Application of U.S. Treaties to Hybrid Entities

Amtrak Prevails in Refund Suit Involving the Federal Communications Excise Tax

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