The top US tax controversies in 2016

October 07 2016

There have been a number of significant developments in the area of US tax controversies during 2016. Fenwick & West highlight some of the top US tax cases from this year, including several large § 482 transfer pricing cases that could provide helpful insight for taxpayers who may be facing similar significant transfer pricing adjustments.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

This week in tax: EU nations drop US pillar two carve-out objections

The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team

Sam Sholli, December 19 2025

Direct Tax

Hogan Lovells, Cadwalader to merge in ‘largest combination in history’

A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific

Noemi Distefano, December 18 2025

Direct Tax

Whose tax is it anyway – Libya’s permanent establishment conundrum

Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises

Salaheddin El Busefi , December 18 2025

Indirect Tax

HMRC scores Supreme Court VAT victory over Hotel La Tour

Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity

Sam Sholli, December 17 2025

Direct Tax

EY recruits provided AI training but still taught ‘old way’

Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR

Sam Sholli, December 17 2025

Direct Tax

KPMG reports 7.5% tax and legal services revenue increase

AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said

Sam Sholli, December 16 2025

Direct Tax

US Treasury secretary eyes pillar two deal finalisation this week

In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line

Tom Baker, December 16 2025

Direct Tax

Winston & Strawn and Taylor Wessing merger confirmed, new brand unveiled

A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices

Noemi Distefano, December 15 2025

Direct Tax

Italy’s opaque tax system underlies in-house discontent, advisers say

As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules

Tom Baker, December 15 2025

Direct Tax

A taxing week: HMRC’s GfC13 puts tax advisers in an unwinnable situation

The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations

Tom Baker, December 12 2025