Overview

Dewey & LeBoeuf’s regular focus on tax controversy and litigation.


In this issue:
- Swiss Court Prevents Disclosure of Some UBS Data to the US; Same Court Earlier Found FINMA Exceeded Authority by Releasing Names of UBS Clients
- IRS Tax Exempt Bond Office Increasing Enforcement Efforts
- New Total Return Swap Audit Guidelines Reveal Scope of IRS Query
- DOJ Issues Guidance Regarding Criminal Discovery Practices
- UBS Issues Code of Business Conduct and Ethics
- Wells Fargo Denied $115 Million Refund in SILO Case
- Textron Appeals First Circuit’s Decision to Supreme Court
- Tax Court Rules on Listed Transactions
- IRS Prevails in Tax Court and Secures 40 Percent Accuracy-Related Penalty Where Taxpayer’s Partnership Transaction Involved Offsetting Market-Linked Deposit Contracts
- Veritas Software Corp., et al. v. Commissioner: IRS Suffers Billion-Dollar Tax Court Loss in Transfer Pricing Dispute
- Supreme Court Requests Solicitor General Input on Retroactive Tax Collection
- Tax Lawyer Pleads Guilty to Attempting to Evade Tax
- Update on Enforcement Actions Relating to Section 6707A


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