Winter Newsletter 2019

On January 17, 2020, a federal district court in Washington ordered Microsoft Corporation (“Microsoft”) to produce many documents to the Internal Revenue Service (“IRS”) that Microsoft asserted were privileged. Microsoft had argued that most of the documents were protected by protected by the work product doctrine and the federally authorized tax practitioner privilege set forth

In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor examines a recent transfer pricing decision from the Western District of Washington, in which a Washington federal judge took a broad interpretation of what constitutes a tax shelter when he ordered Microsoft to turn over documents to the IRS.

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On December 19, 2019, in a split decision in Texas v. United States, the Fifth Circuit held that the Individual Mandate (“Mandate”) of the Patient Protection and Affordable Care Act (“ACA”) became unconstitutional when Congress zeroed out the penalty, but vacated the district court’s decision that the ACA itself was unconstitutional without the Mandate.