United States:
Focus On Tax Controversy And Litigation: Tax Court Holds Against Taxpayer In LILO/SILO Case John Hancock
17 October 2013
Shearman & Sterling LLP
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This month's newsletter features articles about the
agreement between Switzerland and the United States to permit some
Swiss banks to participate in a settlement program and avoid
criminal prosecution over accounts maintained by US taxpayers; the
First Circuit's decision in Sun Capital, in which the First
Circuit found that a private equity fund was engaged in a
"trade or business" for ERISA purposes; and the Fifth
Circuit's decision in Nevada Partners, affirming the trial
court's decision that FOCus transactions lacked economic
substance and application of the negligence penalty despite the
taxpayers' reliance on outside attorneys and accountants.
View newsletter, "Focus on Tax Controversy and Litigation: Tax
Court Holds Against Taxpayer in LILO/SILO Case John
Hancock".
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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