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APA Challenge To Notice Of Deficiency: QinetiQ Oral Arguments
On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192.
United States
4 Nov 2016
2
Altera Corporation Files Answering Brief In Commissioner's Ninth Circuit Appeal Of Altera
In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...
United States
21 Sep 2016
3
3M Company, IRS File Reply Briefs In "Blocked Income" Case; Tax Court Orders Oral Argument
3M returns to its argument that Treas. Reg. § 1.482-1(h)(2) is "procedurally invalid" because Treasury and the IRS failed to satisfy the requirements of section 553 of the APA when they promulgated the regulations.
United States
8 Sep 2016
4
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
5
Supreme Court Issues Opinion Addressing Interplay Between APA Procedural Compliance And Chevron Difference
In Encino Motorcars, LLC v. Navarro, Sup. Ct. No. 15-415 (June 20, 2016), the Supreme Court of the United States invalidated a regulation issued by the US Department of Labor under the Fair Labor Standards Act.
United States
6 Jul 2016
6
Altera: How To Challenge Tax Regulations On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under section 482 requiring participants in qualified cost-sharing agreements (CSAs) to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
5 Oct 2015
7
Statute Of Limitation: Congress Overrules Home Concrete And Retroactively Removes Some Taxpayer Defenses
On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law.
United States
20 Aug 2015
8
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
9
The New Section 6501(c)(10) Regulations
Under § 6501(a), the IRS generally has three years from the date a tax return is filed to assess additional tax.
United States
24 Apr 2015
10
Ensuring Timely Filing With Private Delivery Services
Most of us are aware of the timely-mailed-timely-filed "mailbox rule" contained within the Internal Revenue Code.
United States
4 Jun 2014
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