Search for: "Cooper v. Commissioner of Internal Revenue"
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31 Dec 2019, 8:13 am
However, CA RIAs can avoid these additional requirements by engaging an auditor (that is an independent public accountant registered with the PCAOB) to prepare and distribute audited financial statement to all investors ( or other beneficial owners_ of the pooled investment vehicle, and to the Commissioner of the California Department of Business Oversight (“DBO”). [read post]
25 May 2019, 7:19 am
§ 7701(a)(14) as “any person subject to any internal revenue tax. [read post]
10 May 2019, 3:00 am
This Wachtell Lipton memo summarizes the implications of the case for companies using internal investigations as a tool for cooperating with governmental authorities: The lesson for companies conducting internal investigations is not, of course, to stop cooperating with governmental inquiries. [read post]
2 Apr 2019, 6:50 am
In Barrick Gold Corp. v. [read post]
21 Feb 2019, 4:00 am
Court of Appeal’s ruling in R. v. [read post]
3 Apr 2018, 9:03 am
Conversely, Justice Antonin Scalia’s federal-tax opinions, such as the 2,744-word opinion in Commissioner of Internal Revenue v. [read post]
15 Dec 2017, 9:01 am
CA RIAs to pooled investment vehicles may avoid the independent party and surprise examinations requirements by having audited financial statements prepared by an independent public accountant registered with the PCAOB and distributing such audited financial statements to all limited partners (or members or other beneficial owners) of the pooled investment vehicle, and to the Commissioner of the California Department of Business Oversight (“DBO”). [read post]
15 Dec 2017, 9:01 am
CA RIAs to pooled investment vehicles may avoid the independent party and surprise examinations requirements by having audited financial statements prepared by an independent public accountant registered with the PCAOB and distributing such audited financial statements to all limited partners (or members or other beneficial owners) of the pooled investment vehicle, and to the Commissioner of the California Department of Business Oversight (“DBO”). [read post]
28 Nov 2017, 12:19 pm
The report noted that Internal Revenue Code § 7433 provides that a taxpayer may bring a civil action for damages against the Federal Government if an officer or employee of the IRS recklessly or intentionally, or by reason of negligence, disregards any provision of the Internal Revenue Code or related regulation in connection with the collection of Federal tax. [read post]
30 Jul 2017, 1:17 pm
The memo stated that, pending the outcome of the pilot, the guidance may be incorporated into the Internal Revenue Manual. [read post]
30 Jul 2017, 1:17 pm
The memo stated that, pending the outcome of the pilot, the guidance may be incorporated into the Internal Revenue Manual. [read post]
14 Apr 2017, 6:07 am
Cooper, Luke A. [read post]
21 Jul 2016, 10:00 pm
Commissioner of Internal Revenue, Docket Nos. 2685-11, 8393-12 (U.S. [read post]
6 Jun 2016, 1:00 am
On Thursday 9 June it will hear the compliance cost issues in the cases of Price Waterhouse Coopers v Saad Investments Company Ltd & Anor (Bermuda) and Singularis Holdings Ltd v Price Waterhouse Coopers (Bermuda). [read post]
28 Apr 2016, 11:29 am
[emphasis added] While most search engines are commercial enterprises and supported by advertising revenue, it does not charge users for search results and it does not charge content providers to be indexed in the search engine for inclusion in search results. [read post]
8 Apr 2016, 9:10 am
Commissioner of Internal Revenue, 309 U.S. 304, 306–09, 60 S.Ct. 566, 567–69, 84 L.Ed. 770 (1940). [read post]
6 Jan 2016, 5:08 pm
Such term includes a return prepared pursuant to section 6020(a) of the Internal Revenue Code of 1986, or similar State or local law, or a written stipulation to a judgment or a final order entered by a nonbankruptcy tribunal, but does not include a return made pursuant to section 6020(b) of the Internal Revenue Code of 1986, or a similar State or local law. [read post]
8 Sep 2015, 5:08 pm
First, in a July 8, 2015 decision in Acevedo v. [read post]
24 Feb 2015, 5:04 pm
Avakian also discussed the impact of the Second Circuit’s recent decision in United States v. [read post]
7 Jan 2015, 10:00 pm
Commissioner of Internal Revenue, Texas Tax Court Judge Ronald Buch ruled that the petitioners “may use predictive coding in responding to respondent’s discovery request” and if “after reviewing the results, respondent believes that the response to the discovery request is incomplete, he may file a motion to compel at that time”. [read post]
