U.S. Supreme Court,
Tax,
Corporate,
Civil Litigation
Mar. 11, 2020
Corporate tax allocation agreements: No longer subject to federal common law
The U.S. Supreme Court recently struck down a federal common law interpretation of tax allocation agreements and further cautioned federal courts about federal common lawmaking.
Stephen J. Turanchik
Attorney
Paul Hastings LLP
Email: stephenturanchik@paulhastings.com
Stephen is an attorney in the Tax practice of Paul Hastings and is based in the firm's Los Angeles office. Mr. Turanchik's practice focuses on tax controversy and litigation at the state and federal levels and tax advice on international reporting.
Douglas A. Schaaf
Partner
Paul Hastings
Email: dougschaaf@paulhastings.com
Douglas is chair of the Global Tax Practice of Paul Hastings and is based in the firm's Orange County office. He provides tax and business advice relating to complex business transactions and issuance of financial instruments.
The U.S. Supreme Court in Rodriguez v. FDIC, 140 S. Ct. 713 (2020),unanimously struck down a federal common law interpretation of tax allocation agreements and further cautioned federal courts about federal common lawmaking.
Prior to the financial crisis of the late 2000s, United Western Bancorp, Inc. and its subsidiaries filed consoli...
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