Honorable Amalya Kearse - U.S. Court of Appeals for the Second Circuit.
Won tax case for Procter & Gamble involving foreign sales corporations.
Won summary judgment for GM in car repair tax assessment cases.
Represented Procter & Gamble in $435 million tax refund suit.
Cable Tax Policy Meeting (March 26-28, 2018)
The Eversheds Sutherland (US) tax team presents at the Cable Tax Policy Meeting on March 26-28, 2018 in Charleston, South Carolina. Details of their presentations are below. “Transaction ...
Best Practices for Protests and Litigation (May 21, 2015)
TEI Audits & Appeals Seminar
Sutherland Partners Daniel Schlueter and Marc Simonetti present Best Practices for Protests and Litigation at the TEI Audits & Appeals Seminar on May 21 in San Francisco, California. In this ...
Defending Taxpayer Penalties (May 20, 2015)
TEI - Audits & Appeals Seminar
Sutherland Partner Dan Schlueter presents Defending Taxpayer Penalties at the TEI - Audits & Appeals Seminar on May 20, 2015, in San Francisco, CA.
Class Action Lawsuits and False Claims Act Suits: Protecting Your Company (May 15, 2015)
TEI Los Angeles Chapter
Sutherland attorneys Daniel H. Schlueter and Andrew Appleby presents Class Action Lawsuits and False Claims Act Suits: Protecting Your Company at the TEI Los Angeles Chapter Meeting in Studio City, ...
We Can Settle Up at the Drive-In (May 15, 2015)
TEI Los Angeles Chapter
Sutherland Partners Michele Borens, Jeffrey A. Friedman and Daniel H. Schlueter present We Can Settle Up at the Drive-In at the TEI Los Angeles Chapter Meeting in Studio City, California on May 15.
Settlement and Litigation: Best Practices and Strategies and Nationwide State Tax Case Developments (March 26, 2014)
TEI Detroit Chapter
Sutherland Tax Partners Carley A. Roberts, Daniel H. Schlueter and Marc A. Simonetti present at the Tax Executives Institute (TEI) Detroit Chapter meeting at The Henry in Dearborn, Michigan on March ...
Awards and Rankings
Selected as a Washington, DC Future Litigation Star by Benchmark Litigation (2011-2017)
Recognized by The Legal 500 United States in the area of tax controversy (2011)
Selected for inclusion in Washington, D.C., Super Lawyers Rising Stars (2005-2007, 2009)
Selected for inclusion in Georgia Super Lawyers “Rising Stars” (2005-2009)
“Eversheds Sutherland (US) has been at the forefront of federal tax practice since the founding of the firm in the 1920s. Today, we have one of the country’s deepest and most highly regarded tax practices, with particular expertise in all phases of tax controversy and litigation.”
Legal Alert: IRS Begins to Target Management Fee Waivers on Audit (February 23, 2017)
According to a recent BNA news report, the Internal Revenue Service (IRS) has proposed adjustments and penalties to a private fund manager related to its use of management fee waivers and transaction ...
Legal Alert: LB&I to Closely Scrutinize Basket Transactions (February 21, 2017)
The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds ...
Legal Alert: Taking Stock in Related-Party Debt: Regulations Propose Sweeping Changes (April 7, 2016)
On April 4, the Treasury and the Internal Revenue Service (IRS) released proposed regulations under IRC 385 (the Proposed Regulations)1 that are intended to combat perceived concerns associated ...
Legal Alert: Revised LB&I Examination Process Requires Taxpayer’s Written Acknowledgement of Facts for Unagreed Issues (March 7, 2016)
Recently announced changes to the Internal Revenue Service (IRS) Large Business and International (LB&I) Division’s examination process include a requirement that the audit team issue an Information ...
Legal Alert: Tax Court Holds that Residual Value Insurance Qualifies as Insurance for Tax Purposes (September 24, 2015)
On September 21, the United States Tax Court held in favor of the taxpayer in R.V.I. Guaranty Co., Ltd. and Subsidiaries v. Commissioner, 145 T.C. No. 9 (2015). The court concluded that the ...
Legal Alert: The Tax Court Approves the Use of Predictive Coding (September 29, 2014)
On September 17, the U.S. Tax Court, in Dynamo Holdings LP v. Commissioner, 143 T.C. No. 9 (Sept. 17, 2014), held that a taxpayer could use predictive coding, over the objection of the Internal ...
Legal Alert: The 2013 Tax Litigation Year in Review: Important Events (January 30, 2014)
As we look forward to 2014, we take a look back at the top 10 important tax controversy issues making the news in 2013 that may have continuing importance in the future.Woods - Court Rules ...
Legal Alert: U.S. Supreme Court Resolves Circuit Split: Holds Valuation Misstatement Penalty Applies in Partnership Tax Shelter Case and Federal District Court Has Jurisdiction to Determine Provisional Applicability of Penalty Assessed to Partners (December 19, 2013)
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had ...
Legal Alert: U.S. District Court Orders Disclosure of Tax Accrual Workpapers, but Protects Opinion Work Product Information (June 18, 2013)
On June 4, 2013, the U.S. District Court for the District of Minnesota held that certain information contained in tax accrual workpapers must be disclosed by the taxpayer pursuant to an Internal ...
Legal Alert: Supreme Court Unanimously Rules in Favor of Taxpayer, Holds U.K. Windfall Tax Creditable (May 22, 2013)
The United States Supreme Court held Monday in PPL Corporation v. Commissioner (No. 12-43) that a U.S. taxpayer was entitled to claim a foreign tax credit on its share of a “windfall tax” imposed on ...
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