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United States: Adams challenge – A ‘challenge’ for taxpayers, or an opportunity?
Regulatory NewsIn brief On 21 January 2021, the Tax Court decided Adams Challenge (UK) Ltd. v. Commissioner, 156 T.C. No. 2, 2021 BL 19487 (2021), denying deductions to a foreign corporation because it filed its returns after the IRS had prepared returns on its behalf. Adams Challenge disputed Treas. Reg. § 1.882-4(a)(3)(i), requiring “timely” returns (defined […]
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United States: ‘Flora’ full payment rule does not apply to FBAR penalties
Regulatory NewsIn brief In Mendu v. United States, the Court of Federal Claims held that penalties for failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), commonly known as “FBAR penalties,” were not subject to the Flora full payment rule, which requires a plaintiff to make payment of the full tax amount before […]
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United States: Want to claim solar energy tax credits? Lessons on how to avoid common foot-faults in structuring transactions
Regulatory NewsIn brief Tax equity financing transactions have become an increasingly popular way to provide a higher rate of return for outside investors and to help developers monetize an otherwise cost prohibitive project. In a recent Tax Court decision, Olsen v. Commissioner, T.C. Memo. 2021-41 (6 April 2021), the taxpayers invested in such a venture, but the […]
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United States: First United States-Mexico-Canada Agreement Environment Committee meeting
Regulatory NewsOn May 18, 2021, the Office of the United States Trade Representative (USTR) published in the Federal Register a notice that the Parties to the United States-Mexico-Canada Agreement (USMCA) intend to hold the first meeting of the Environment Committee (Committee) virtually, on June 17, 2021. Following the government-to-government meeting, the Committee will hold a virtual public session. The Office […]
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United States: This Week in Government Enforcement (Video Chat)
Regulatory NewsIn brief Please join us for a new weekly video series, hosted by Baker McKenzie’s North America Government Enforcement partners Tom Firestone and Jerome Tomas. This weekly briefing is available on demand and will cover hot topics and current enforcement actions related to white collar crime and criminal investigations in the US and abroad to arm […]
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