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Tax Court Tax Appeals Tax Liability

Cadwalader, Wickersham & Taft LLP

Burlington: Good News for the Secondary Debt Market

In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...more

Cadwalader, Wickersham & Taft LLP

Complex Borrowing and Group Structures

The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Cadwalader, Wickersham & Taft LLP

Liberty Global to Appeal Its Foreign Tax Credit Tax Court Loss

Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on...more

Cadwalader, Wickersham & Taft LLP

Pre-Closing Special Dividends: Distributions or Sales Proceeds?

A recent pair of decisions by the California Office of Tax Appeals examined the tax treatment of special dividends paid in connection with the acquisition of a corporate target. Private company acquisitions are...more

Freeman Law

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Stikeman Elliott LLP

Raising New Arguments and Issues in Tax Litigation

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Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more

Gray Reed

Going to Appeals – Preparing the Protest

Gray Reed on

Overview of the Appeals Process - The goal of the Appeals Office is to settle as many cases as possible within the broad guidelines of its Mission Statement...more

Jones Day

Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office

Jones Day on

This video is the second in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage two – the IRS Office of Appeals. He describes the office as having one mission – to...more

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