Timothy S. Shuman

Subscribe to Timothy S. Shuman's Posts
Timothy (Tim) S. Shuman focuses his practice on corporate and international tax matters for US and non-US multinationals, with particular emphasis on domestic and cross-border acquisitions, dispositions, restructurings and liquidations. He has extensive experience in structuring spin-offs and tax-free reorganizations involving publicly traded and privately held companies, and regularly represents clients in obtaining private letter rulings and other guidance from the Internal Revenue Service (IRS). He also works on tax issues involving regulated investment companies. Read Tim Shuman's full bio.

Federal District Court Rules Codified Economic Substance Doctrine Vitiates Tax Transaction Benefits

By , and on Nov 3, 2023
Posted In Court Procedure Matters, Trial Courts

On October 31, 2023, the US District Court for the District of Colorado, in Liberty Global, Inc. v. United States, applied the codified economic substance doctrine and held—on summary judgment—that Liberty Global, Inc. (LGI) must recognize $2.4 billion in taxable gain. At issue was a four-step transaction that took place in 2018, as a result...

Continue Reading

Taxpayers Already Seeking to Hold Treasury and IRS to Policy Statement

By and on Mar 20, 2019
Posted In IRS Guidance, Uncategorized

On March 5, 2019, the US Department of Treasury (Treasury) issued a policy statement on the tax regulatory process. We previously wrote an article for Law360 on the policy statement, which can be accessed here. In our article, we noted the disclaimer language in the policy statement that “is not intended to, and does not,...

Continue Reading

Law360: Significant Changes in IRS Regulatory Process Ahead

By and on Mar 13, 2019
Posted In IRS Guidance, Uncategorized

We recently wrote an article for Law360 on the US Department of Treasury’s policy statement on the tax regulatory process. The Law360 article, “Significant Changes in IRS Regulatory Process Ahead,” can be accessed here.

Continue Reading

Government Files Its Brief in Auer Deference Case

By and on Feb 27, 2019
Posted In Court Procedure Matters, Tax Reform, Uncategorized

As we discussed in a prior post and in our article for Law360, the Supreme Court is poised to decide in Kisor v. Wilkie whether to overrule the Auer deference doctrine. This doctrine, which originated in the 1945 Seminole Rock case, generally affords controlling deference to an agency’s interpretation of its own ambiguous regulations. To...

Continue Reading

Proposed Regulations under Section 956 Provide Benefits for Corporate Taxpayers

By , and on Nov 20, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On October 31, 2018, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations (REG-114540-18) (the Proposed Regulations) that would prevent, in many cases, income inclusions for corporate US shareholders of controlled foreign corporations (CFCs) under section 956. As a result, among other considerations, the Proposed Regulations could significantly expand...

Continue Reading

Tax Reform Insight: US Tax Costs Significantly Reduced on Sale of CFC Stock

By , , and on Sep 13, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

Following the 2017 Tax Act, the US tax costs to a corporate US shareholder that sells stock in a controlled foreign corporation (CFC) are significantly reduced. Beginning in 2018, the amount of gain will be generally less than in prior years and most or all such gain will frequently not be subject to any US...

Continue Reading

Tax Takes Video: Issues Facing CFCs

By , and on Apr 11, 2018
Posted In Tax Reform, Uncategorized

Partners Alexander Lee, Tim Shuman, Britt Haxton and Jay Singer discuss novel concerns facing CFCs in light of tax reform.

Continue Reading

Tax Reform Conference Committee Reaches Agreement

By , , , and on Dec 18, 2017
Posted In IRS Guidance, Tax Reform, Uncategorized

A House-Senate conference committee has reached agreement on a compromise version of the Tax Cuts and Jobs Act, which includes substantial changes to the corporate and international business taxation rules. The stage now appears to be set for final passage and enactment of the legislation before the end of 2017. Continue Reading.

Continue Reading

Read the October Issue of Focus on Tax Strategies & Developments

By , , , , , , , and on Nov 1, 2017
Posted In Court Procedure Matters, IRS Guidance, State Controversy, Tax Reform, Tax Refunds, Transfer Pricing Resource, Trial Courts, Uncategorized

The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues. Republican Leaders Release Tax Reform Framework By David G. Noren Alexander Lee M&A Tax Aspects...

Continue Reading

M&A Tax Aspects of Republican Tax Reform Framework

By , and on Oct 11, 2017
Posted In Tax Reform, Uncategorized

The outline of pending tax reform provisions remain vague, but a significant impact on M&A activity is expected by way of corporate tax cuts, interest deductibility, changes to the expensing of capital investments, a reduction of the pass-through tax rate and changes to our international (territorial) tax system. Continue Reading

Continue Reading




jd supra readers choice top firm 2023 badge