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We are pleased to enclose the February issue of Tax News and Developments, a publication of Baker McKenzie’s North America Tax Practice Group. This month’s edition features a discussion on three Tax Court opinions under section 6751 (b), final withholding regulations, a review of final and proposed BEAT regulations and more!

In this Issue

  • Transformation of “Initial Determination” to “Definite Decision” in Penalty Approval Case
  • Final Withholding Regulations Provide Some Taxpayer Relief
  • A Review of the Final and Proposed BEAT Regulations
  • IRS BEATs on Partnerships with Final Section 59A Regulations
  • Proposed Section 162(m) Regulations: A Due Diligence Disaster
  • The Illinois Appellate Court Shuts the Door on the Secretary of State’s Aggressive Attempt to Subject An Out-of State Corporation to Double Taxation
  • Passing-through the SALT Deduction Cap: New Jersey Edition
  • DAC6: The EU’s Mandatory Disclosure Regime
  • Getting Better All the Time…Baker McKenzie Adds New Talent to its Miami Office
Author

Joy Williamson is a partner in Baker McKenzie’s Tax Practice Group. She routinely represents taxpayers at various stages of tax controversies, including audit, administrative appeals and judicial proceedings. She also has experience in domestic and international tax structuring and planning.

Author

Merritt Rose is an associate in the North America Tax Practice Group and resides in the Firm's Dallas Office. Prior to joining the Firm, Merritt practiced public accountancy at a Big 4 accounting firm. Merritt is also a certified public accountant licensed in Texas.

Author

Brendan Sponheimer is an associate in the New York office of Baker McKenzie and a member of the Tax Practice Group. Prior to joining the Firm, Brendan was a Tax Controversy and Transfer Pricing Associate in New York, and an Attorney Advisor for Judge Joseph Robert Goeke of the United States Tax Court in Washington, D.C.

Author

Rebecca Lasky is a member of Baker McKenzie's Tax and Wealth Management Practice Groups in New York.

Author

Dinh Tran is an associate in the Firm's Tax group in Washington, DC. She advises clients on domestic & international transactional tax matters within the context of mergers and acquisitions, divisions, restructurings, formations, joint ventures, refinancing, and syndications. Dinh represents business clients before the IRS, particularly those seeking private letter rulings and those who are under examination or before IRS Appeals. Prior to joining the Firm, Dinh worked at the Washington National office of a public accounting firm and served as an attorney-advisor at the IRS Office of Chief Counsel, Passthroughs and Special Industries, where she focused on partnership taxation. Also, Dinh previously served as an attorney-advisor to the Honorable Elizabeth Crewson Paris of the United States Tax Court. In addition to practicing tax law, Dinh is currently teaching an ethics course in the taxation program at Georgetown University Law Center.

Author

Drew Hemmings is a member of Baker McKenzie’s North America Tax Practice Group where he focuses his practice on state and local tax matters. Prior to joining the Firm, Mr. Hemmings was a state and local tax consultant with a national accounting firm.

Author

Trevor Mauck is a member of the Firm’s North America Tax Practice Group in the New York office and practices in the area of tax planning and tax controversy.

Author

Megan is a Dutch lawyer with more than seven years experience with tax dispute resolution, procedural tax law, international tax law, DAC6 (Mandatory Disclosure) and transactional work. She represents clients during all stages of tax disputes, including (cross-border) audits, administrative appeals and litigation and she assists clients with tracking global tax controversies, MAP procedures and legal opinions. Her experience encompasses a broad range of issues, including disputes on: transfer pricing, business restructurings, corporate income tax, information obligations, exchange of information, effective place of management and tax residency/permanent establishments. Megan represents clients from a wide variety of industry sectors before the tax courts in the Netherlands and advises clients in a wide variety of industry sectors on tax matters. Megan spent a year on secondment in our Chicago office with the US Tax Controversy team and has experience with US and international tax controversies. She also advises clients in a wide variety of industry sectors on tax matters and mergers and acquisitions, including but not limited to due diligence, SPA negotiations, W&I policy negotiations and specific Tax Insurance policy negotiations.