International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement
Cookies Settings

Swallows Holding case shows timing is critical to tax deductions

March 01, 2008
Share

Swallows Holding has become a talking point among US tax professionals for what it says about timely returns. Jim Fuller, of Fenwick & West, explains why the appeal court reversed the US Tax Court's initial finding

Unlock this article.

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

To unlock this article:

Take a Free Trial or Login

Tags

FeatureUnited StatesTax DisputesITR MagazineMarch 2008Jurisdictions
more across site & bottom lb ros

More from across our site

Gavel of judge with coins against European Union flag
Opinion: EU tax disputes make the case for reform
The European Commission wanted to make an example of US companies like Apple, but its crusade against ‘sweetheart’ tax rulings may be derailed at the CJEU.
Josh White, June 01, 2023
oecd tp training 2000.jpg
OECD transfer pricing training in West Africa coming to an end
The OECD has announced that a TP training programme is about to conclude in West Africa, a region that has been plagued by mispricing activities for a number of years.
Euan Healy, June 01, 2023
Progress on EU public CbCR is a significant move forward on tax transparency
Transparency principles for international tax reform
Richard Murphy and Andrew Baker make the case for tax transparency as a public good and how key principles should lead to a better tax system.
Richard Murphy, May 31, 2023
Hannover, Lower Saxony, Germany - September 26, 2021: Logo of pw
Nine partners suspended in PwC tax scandal latest
‘Go on leave, effective immediately’, PwC has told nine partners in the latest development in the firm’s ongoing tax scandal.
Euan Healy, May 30, 2023
Conference Schaffner 2000.png
ITR Indirect Tax Forum 2023: Govts turning companies into ‘free’ VAT auditors
The forum heard that VAT professionals are struggling under new pressures to validate transactions and catch fraud, responsibilities that they say should lie with governments.
Euan Healy, May 26, 2023
AdobeStock_494001486_Editorial_Use_Only (1).jpg
OECD paper raises potential carbon tax improvements
The working paper suggested a new framework for boosting effective carbon rates and reducing the inconsistency of climate policy.
Euan Healy, May 26, 2023
jonathan-kemper-chatgpt.jpg
This week in tax: TaxGPT becomes 'first' AI-powered tax assistant
UAE firm Virtuzone launches ‘TaxGPT’, claiming it is the first AI-powered tax tool, while the Australian police faces claims of a conflict of interest over its PwC audit contract.
Josh White, May 26, 2023
mohamed-m-apple.jpg
Analysis: EU Commission’s last chance to beat Apple
The US technology company is defending its past Irish tax arrangements at the CJEU in a final showdown that could have major political repercussions.
Josh White, May 25, 2023
Data currency 2000.jpg
ITR Indirect Tax Forum 2023: Meta VAT investigation could 'blow up'
ITR’s Indirect Tax Forum heard that Italy’s VAT investigation into Meta has the potential to set new and expensive tax principles that would likely be adopted around the world
Euan Healy, May 24, 2023
MELBOURNE, AUSTRALIA - JULY 30, 2018: PwC headquarters building
Former PwC Australia partner faces criminal investigation over tax leaks
Police are now investigating the leak of confidential tax information by a former PwC partner at the request of the Australian government.
Courtney Wilson, May 24, 2023