Appeals Court Upholds Timely Filing Requirement for Foreign CorporationsHoward LeventhalMatthew S. Blum, Ernst & Young
June 1, 2009 A return filing date is not the only benchmark for measuring the six-year time limit within which the government must begin a prosecution for tax evasion under IRC § 7201. Criminal defendant Leonard Widman found that out when the U.S. District Court for the District of Conne...
Filing a refund claim for overpaid taxes is not a problem for most taxpayers. Generally, taxpayers may file such claims within three years of the date the return was filed or two years from the date the tax was paid, whichever is l...
Court of Appeals for the Third Circuit reversed the 2006 split decision of the Tax Court. The decision includes reviving a U.S. Treasury Regulation that disallows the deductions of foreign corporations filing income tax returns.CohenWashington
Third Circuit Court of Appeals ruling in a case between Swallows Holding Ltd. and the Internal Revenue Service (IRS) commissioner regarding the timely tax filing requirement of the Treasury regulation. The taxpayer in Swallows was a Barbados corporation that held real property located in the U.S....
Seventh Circuit Reinstates Indiana Lawsuit On Cost Recovery, Says Filing Was TimelyA federal appeals court on March 17 reinstated as timely a cost recovery lawsuit filed under Indiana's hazardous substances law, basing its decision on a recent Indiana Supreme Court opinion (Commercial Logistics Corp...