Global Tax Controversy and Litigation

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New IRS Guidance on Acceptance of Advance Pricing Agreement (APA) Submissions and Increased Pre-Submission Review

Our lawyers discuss new internal procedures for handling requests for Advance Pricing Agreements introduced by the IRS’s Treaty and Transfer Pricing Operations director.

Client Alert | May 25, 2023

Who’s Who Legal Recognizes 39 Gibson Dunn Partners in its Inaugural Thought Leaders USA Guide

The inaugural edition of Who’s Who Legal’s Thought Leaders: USA featured 39 partners from Gibson Dunn.

Firm News | January 9, 2023

IRS and Treasury Issue Interim Guidance Addressing the Corporate Alternative Minimum Tax

Our lawyers discuss new guidance on the corporate alternative minimum tax enacted under the Inflation Reduction Act of 2022.

Client Alert | January 6, 2023

IRS and Treasury Issue Proposed Regulations Narrowing Domestically Controlled REIT Qualification Test and Revising Section 892 Exemption, as Well as Final Regulations Relating to Qualified Foreign Pension Funds

Gibson Dunn lawyers review proposed regulations by the IRS and the Department of the Treasury relating to REITs, controlled commercial entities and qualified foreign pension funds.

Client Alert | January 4, 2023

Penalty Relief Available: Recent Jurisprudence Offers the Opportunity for Significantly Lower Fines and Other Penalties in White Collar Resolutions with DOJ and Other Agencies

Gibson Dunn lawyers review a ruling by a U.S. federal court of appeals that could reduce penalties in some cases, including negotiated resolutions.

Client Alert | January 3, 2023

IRS and Treasury Issue Interim Guidance on New Stock Buyback Excise Tax

Our lawyers discuss interim guidance provided by the IRS and the Department of Treasury to taxpayers addressing the application of the new excise tax on certain repurchases of corporate stock mandated by The Inflation Reduction Act of 2022.

Client Alert | January 3, 2023

IRS and Treasury Issue Proposed Regulations on Consolidated Group Ownership of CFC Stock for Certain Purposes

Our lawyers discuss proposed IRS and Treasury regulations relating to the consolidated group ownership of the stock of lower-tier controlled foreign corporations.

Client Alert | December 16, 2022

Proposed U.S. Foreign Tax Credit Rules Provide Relief for Certain Taxpayers and Ideas for Others

Gibson Dunn lawyers discuss proposed regulations to address certain concerns raised by taxpayers and other stakeholders in response to final foreign tax credit regulations published in January 2022.

Client Alert | December 1, 2022

Gibson Dunn Ranked in World Tax 2023

World Tax, International Tax Review’s annual guide to the world’s leading tax advisory practices, has recognized Gibson Dunn in five categories in its 2023 edition.

Firm News | September 29, 2022

11 Gibson Dunn Partners Named Lawyers of the Year

Best Lawyers® named 11 Gibson Dunn partners as the 2023 Lawyer of the Year in their respective practice areas and cities.

Firm News | August 18, 2022

Update: Senate Passes Revised Version of Inflation Reduction Act of 2022; Carried Interest Changes Omitted and Tax on Corporate Stock Buybacks Added

On August 7, 2022, the Senate voted 51-50 to pass the Inflation Reduction Act of 2022, which broadly addresses climate change, taxes, health care, and inflation. The action sends the measure to the House of Representatives for a vote as early as Friday of this week. 

Client Alert | August 10, 2022

Inflation Reduction Act of 2022 Would Modify the Tax Treatment of Carried Interests, Include a Corporate Minimum Tax, and Expand Clean Energy Tax Incentives

On July 27, 2022, Senator Joe Manchin (D-West Virginia) and Senator Majority Leader Chuck Schumer (D-New York) announced an agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 to address climate change, taxes, health care, and inflation.

Client Alert | July 29, 2022

Gibson Dunn Recognized in Chambers High Net Worth 2022

Gibson Dunn was recognized in the 2022 edition of Chambers High Net Worth, a guide to the leading lawyers and law firms for international private wealth.

Firm News | July 14, 2022

Expert Guides Recognizes Four Gibson Dunn Partners in Tax

Expert Guides has named four Gibson Dunn partners to its 2022 edition of the Tax Expert Guide, which recognizes the top legal practitioners in the industry. 

Firm News | July 8, 2022

Supreme Court Holds That Late Petitions For Review Of IRS Collection Due Process Determinations Are Subject To Equitable Tolling

Today, the Supreme Court unanimously held that the Internal Revenue Code’s 30-day deadline for taxpayers to seek Tax Court review of “collection due process” determinations is a nonjurisdictional claims-processing rule that is subject to equitable tolling.

Client Alert | April 21, 2022

The Biden Administration’s Digital Assets Executive Order and Its Implications

On March 9, 2022, President Biden signed a long-awaited Executive Order regarding the U.S. government’s strategy for digital assets. Our lawyers review the three principal takeaways from the Executive Order.

Client Alert | March 10, 2022

How Justices May Interpret Statutory Time Bar In Tax Context

Washington, D.C. partners Saul Mezei and Terrell Ussing are the authors of "How Justices May Interpret Statutory Time Bar In Tax Context," published by Law360 Tax Authority on January 21, 2022.

Article | January 24, 2022

The Potential for Tax Enforcement Through Subregulatory Guidance

Los Angeles partner Michael Desmond is the co-author of "The Potential for Tax Enforcement Through Subregulatory Guidance," published by Tax Notes Federal on November 15, 2021.

Article | December 13, 2021

Infrastructure Bill’s New Reporting Requirements May Have Sweeping Implications for Cryptocurrency Ecosystem

On November 15, 2021, President Biden signed into law the “Infrastructure Investment and Jobs Act,” which adds new reporting requirements for certain cryptocurrency transactions that have little to do with infrastructure, but could have potentially dramatic implications for millions of United States businesses and consumers who have embraced cryptocurrency for its efficiency, transparency, and accessibility.

Client Alert | November 18, 2021

Gibson Dunn Adds Tax Controversy Group, Led by Sanford Stark, in Washington, D.C.

Gibson, Dunn & Crutcher LLP is pleased to announce that Sanford Stark, Saul Mezei, and C. Terrell Ussing have joined the firm as partners in the Washington, D.C. office.

Press Releases | November 15, 2021

U.S. House Ways and Means Committee Proposes Substantial Extension and Expansion of Clean Energy Tax Incentives

If enacted into law in its current form, the Build Back Better Act would substantially extend and expand available clean energy tax incentives, including the investment tax credit (“ITC”), the production tax credit (“PTC”), and the carbon capture and sequestration credit. Gibson Dunn lawyers examine the current state of the proposed legislation.

Client Alert | October 13, 2021

Senate Finance Committee Chairman Ron Wyden (D-OR) Introduces the “Ending The Carried Interest Loophole Act” That Would Require Current Ordinary Income Inclusions

On August 5, 2021, U.S. Senate Finance Committee Chairman Ron Wyden (D-Oregon) and U.S. Senate Finance Committee member Sheldon Whitehouse (D-Rhode Island) introduced legislation entitled the “Ending the Carried Interest Loophole Act.” According to a summary released by the Finance Committee, the legislation is intended to close “the entire carried interest loophole.”  While this legislation is very similar to a previous proposal introduced by Chairman Wyden, this legislation appears to have a greater likelihood of passage given the Democratic party’s control of both chambers of Congress and the election of President Biden.

Client Alert | August 10, 2021

Biden Administration Releases Fiscal Year 2022 Budget, Together With a “Greenbook” Providing Detailed Descriptions of Proposed Changes to Federal Tax Law and Accompanying Revenue Estimates

On May 28, 2021, the Administration released its fiscal year (FY) 2022 Budget, outlining a plan for $6 trillion of federal spending and $4.1 trillion in revenue for FY 2022 alone.

Client Alert | May 29, 2021

Former IRS Chief Counsel Michael Desmond Joins Gibson Dunn’s Los Angeles and D.C. Offices

Gibson, Dunn & Crutcher LLP is pleased to announce that Michael J. Desmond has joined the firm as a partner in the Los Angeles and Washington, D.C. offices.

Press Releases | May 3, 2021

World Tax Recognizes Sandy Bhogal and Elaine Chen

World Tax, in association with the International Tax Review, has named London partner Sandy Bhogal and Hong Kong partner Elaine Chen among its 2021 Tax Leaders.

Firm News | September 24, 2020

UK Supreme Court Decides Suspending UK Parliament Was Unlawful

On September 23, 2019, the UK’s highest court ruled that Prime Minister Boris Johnson’s decision to suspend (or “prorogue”) Parliament for five weeks, from September 9, 2019 until October 14, 2019, was unlawful.

Client Alert | September 24, 2019

Supreme Court Holds That Payments For Lost Wages Are Taxable “Compensation” Under The Railroad Retirement Tax Act

On March 4, 2019, the U.S. Supreme Court held 7-2 that payments for lost wages due to on-the-job injuries are a form of taxable “compensation” under the Railroad Retirement Tax Act (RRTA).

Client Alert | March 4, 2019