Shearman And Sterling

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Nov 18, 2015

Focus on Tax Controversy and Litigation


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In addition to the discussion of the Second Circuit’s decision in Schaeffler, this month’s issue features articles regarding the “new” IRS Notices covering “Basket Options” and “Basket Contracts”, the Tax Court’s recent transferee liability decision inTricarichi v. Commissioner, two recent decisions from the United Stated District Court relating to the attorney-client privilege and the issuance of “John Doe” summonses for information related to offshore accounts in Belize, Notice 2015-22 which describes best practices to manager the flow of docketed cases between IRS Appeals and the Office of Chief Counsel, and an update on proposed changes to the U.S. Tax Court rules of practice and procedure.

View full newsletter, Focus on Tax Controversy and Litigation