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Blogs / Additional Resources

In November, 2015, Congress repealed TEFRA and enacted an entirely new statutory regime covering examination, litigation, and payment of taxes for partnerships and entities taxed as partnerships. For those seeking information, this site will be a resource with articles, programs, and insights on how to address the new provisions of the Bipartisan Budget Act of 2015. In light of this impending legislation, partnerships and partners should now evaluate the current provisions of their partnership agreements and make fundamental changes to the tax procedure provisions. Doing so now will help to reduce and manage the partnership’s potential tax obligations and administrative costs and define the rights and responsibilities of partners, the partnership, and the partnership representative.  For more information, please email or visit
The Foreign Agents Registration Act (FARA) is over 80 years old, but it has never been more important than now. The U.S. Department of Justice, the U.S. Congress, and other law enforcement bodies have increased their scrutiny and enforcement of FARA compliance, which has given rise to concerns and questions for those who could be foreign agents, including individuals, lobbying firms, political consultancies, public relations firms, law firms, nonprofits, and corporations that work with foreign governments, state-owned enterprises, businesses, NGOs, and individuals. FARA registration, reporting, and compliance can be complex. This website is provided as an informational resource to the regulated community and to journalists wanting to understand FARA. For more information, please email or visit


Additional Resources


Showcase Pages
Bankruptcy & International Insolvency
Increasingly, as markets become global, commercial insolvency cases in the United States are taking on a cross-border dimension. In 2005, the United States Congress added Chapter 15 to the Bankruptcy Code, which incorporates the Model Law on Cross-Border Insolvency adopted in other countries. In addition, foreign debtors with assets in the U.S. are eligible to reorganize and discharge their debts under Chapter 11 of the Bankruptcy Code. In this environment, international companies, who may be unfamiliar with U.S. bankruptcy law and procedures, are nonetheless looking to protect their interests. Caplin & Drysdale's highly skilled insolvency practitioners can help.  For more information, please visit this link or email

Captive Insurance
In 2016, the IRS issued a Notice identifying certain transactions relating to small captive insurance companies as a “transaction of interest.” The IRS has been actively examining captives and their owners and litigating cases in the U.S. Tax Court. The new “transaction of interest” designation throws small captive insurance company transactions into a tax reporting regime that can potentially lead to significant penalties and IRS income tax and promoter examinations. Caplin & Drysdale’s Tax Controversies Group advises on transaction reporting requirements and represents businesses, captives, and managers under IRS examination.  The link above provides access to alerts, articles, and news items for those who may be affected.  For more information, please visit this link or email

International Tax - Transfer Pricing
U.S. corporate tax directors and individuals holding foreign assets face increasing complexities and growing transparency obligations, particularly after the enactment of the Tax Cuts and Jobs Act of 2017 (TCJA), the OECD BEPS initiative, and the EU State Aid investigations. Caplin & Drysdale’s International Tax Group offers seasoned guidance and innovative thinking to address these challenges. After more than five decades of navigating sophisticated cross-border matters for our clients—including transfer pricing, structuring, tax treaty matters, and all manner of controversy—our experience is deep and broad. Lawyers in the Group have formerly held senior roles in the Internal Revenue Service, the Department of Justice, and the Treasury Department, and can offer insight into how U.S. tax law is administered and enforced. Others had senior in-house positions with leading multinational companies, affording a practical perspective. Our collective experience in government, corporate, and private practice allows us to bring a unique combination of technical background, tactical judgment, and problem-solving savvy to resolving our clients’ most-sensitive matters.  For more information, please visit this link or email

Caplin & Drysdale litigators are regularly asked to handle complex business, financial, and commercial disputes that have put a business in peril. We also represent plaintiffs around the world seeking to have their rights vindicated through the court system. Our litigators efficiently handle matters of varying sizes, emphasizing close communication with clients, hands-on involvement by senior lawyers, and lean staffing in relation to the size of the matters we handle. Our aim is to deliver excellent value for our clients. View our brochure.  For more information, please visit this link or email

Nonprofit Tax and Corporate Governance
The rules governing creation, operation, and dissolution of exempt organizations are technical, and careful compliance with these rules is a necessity. If you are an established exempt organization or are thinking of seeking tax-exempt status for your entity, Caplin & Drysdale has the experience you need to accomplish your goals.  For more information, please visit this link or email

Trusts and Estates
Our private client group counsels individuals and families on domestic and cross-border tax and estate planning issues, including the use of trusts, partnerships, corporations, foundations and wills and the application of tax treaties. We also represent domestic and international clients in disputes with the IRS regarding their income, estate, gift and generation-skipping transfer tax liabilities. We help individuals with their tax compliance issues, including pre- and post-immigration issues for international clients. We are one of the few firms with a focus on expatriation. Our attorneys draw upon their vast experience both in private practice and in government service to bring a uniquely informed perspective to our representations.  For more information, please visit this link or email

U.S. Tax Reform
With Tax Reform a priority item for our clients and their advisors, Caplin & Drysdale's tax lawyers remain at the forefront of assisting corporations, individuals, and nonprofits plan for and resolve their most intricate matters. This resource will take you to the most recent developments on how changes to tax law will impact businesses and individuals in the areas of Exempt Organizations, International Tax, Private Client, and Tax Controversies. For more information, please visit this link or email