For decades, large corporate taxpayers under continuous audit have been able to make disclosures under Revenue Procedure 94-69 at the beginning of an examination to notify the Internal Revenue Service (IRS) of adjustments...more
On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more
Almost 11 months ago, the Internal Revenue Service (IRS) released a memorandum regarding the implementation of the Large Partnership Compliance (LPC) Pilot Program, including the identification, selecting and delivery of...more
We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more
1/17/2022
/ Appeals ,
Audits ,
Estate Tax ,
Failure-to-File ,
Federal Taxes ,
Fraud ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Statute of Limitations ,
Tax Court
The traditional audit experience for taxpayers large and small has, like many things, been impacted by COVID-19. Taxpayers and the Internal Revenue Service (IRS) have been forced to navigate audits in a remote environment,...more
Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more
If you have knowingly failed to report income or claimed deductions you know you are not entitled to, or just decided not to file your tax returns and pay the tax owed, you may be liable for civil penalties and even jail time...more
A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency.
In Howe...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
4/18/2019
/ Arms Length Transactions ,
Audits ,
Base Erosion Tax ,
Corporate Taxes ,
Foreign Corporations ,
Foreign Entities ,
Foreign Subsidiaries ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Offshore Banks ,
Offshore Funds ,
Transfer Pricing