Shearman And Sterling

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June 27, 2016

Focus on Tax Controversy and Litigation


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In addition to the discussion of the recently proposed regulations which impose new documentation requirements under Section 385, this month’s issue features articles regarding the Circuit Court decision in Chemtech Royalty Associates v. United States discussing the substantial authority defense to penalties, a survey of recent transferee liability cases involving Midco transactions, Revenue Procedure 2016-30 which provides new procedures to resolve issues through a pre-filing agreement, and Revenue Procedure 2016-19 which describes changes to the Service’s Industry Issue Resolution (“IIR”) Program.

View full memo, Focus on Tax Controversy and Litigation