On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required under...more
On April 8, 2020, the Internal Revenue Service (IRS) released a statement telling taxpayers that guidance would be forthcoming on refund claims related to the Coronavirus Aid, Relief and Economic Security Act, or the CARES...more
Rev. Proc. 2020-23 eases restrictions on partnerships’ ability to file amended tax returns and issue amended Schedules K-1 in order for their partners to avail themselves of the retroactive tax relief provided by the CARES...more
The Coronavirus Aid, Relief and Economic Security Act, or CARES Act, provides tax relief to taxpayers in certain situations. Some of these provisions may generate refunds for prior years, such as the relaxation of...more
In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would...more
In a recent order in the The Cannon Corp. v. Commissioner, No. 12466-16, the US Tax Court (Tax Court) held that a redacted email from a revenue agent’s supervisor to the agent regarding a notice of deficiency was not...more
Recently, the US Federal District Court for the Southern District of Iowa in Meredith Corp. v. United States, No. 4:17-cv-00385 (S.D. Iowa Mar. 20, 2020), held that a magazine publisher was entitled to refund of federal...more
The Internal Revenue Service released a Q&A on Notice 2020-18 to clarify the relief available to taxpayers during the Coronavirus (COVID-19) pandemic. The Q&A offers important new details on the federal income tax filing and...more
3/28/2020
/ Controlled Foreign Corporations ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
Employee Contributions ,
Estate Tax ,
Filing Deadlines ,
Gift Tax ,
Income Taxes ,
Installment Agreements ,
IRS ,
Relief Measures ,
Shareholders ,
Tax Returns ,
Time Extensions
The Internal Revenue Service announced a new initiative to provide taxpayer relief through a variety of measures, including easing payment guidelines and postponing compliance actions in light of the Coronavirus (COVID-19)...more
On March 20, 2020, the Internal Revenue Service expanded its relief for taxpayers in light of the Coronavirus (COVID-19) pandemic. All federal income tax payments and federal income tax returns that were due April 15, 2020,...more
Senate Majority Leader Mitch McConnell (R-KY) introduced a new COVID-19 Relief Package on Thursday. The bill includes numerous tax changes to grant tax relief and provide cash flow and liquidity to businesses. It will also...more
The Federal government has recently taken a series of actions concerning the novel coronavirus disease (COVID-19). We discuss the tax implications of these decisions...more
On March 13, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. We...more
This has been a busy week in the tax appointments world, with the appointment of the new National Taxpayer Advocate (NTA), the reappointment of Chief Judge Foley as Chief Judge of the United States Tax Court (Tax Court), and...more
The United States Supreme Court has picked up the pace this week, already issuing eight regular opinions and four opinions relating to orders as of today. We discuss the tax-related items here.
In Rodriguez v. FDIC, the...more
2/27/2020
/ Administrative Procedure Act ,
Affiliated-Business Arrangements ,
Appeals ,
Bob Richards Rule ,
Consolidated Tax Returns ,
Federal Common Law ,
Federal v State Law Application ,
Internal Revenue Code (IRC) ,
IRS ,
Jurisdiction ,
Kisor v Wilkie ,
Lack of Authority ,
Parent Corporation ,
Petition for Writ of Certiorari ,
Remand ,
Rodriguez v Federal Deposit Insurance Corp. ,
SCOTUS ,
State Law Claims ,
Tax Allocation Agreements ,
Tax Reform ,
Tax Refunds ,
Unconstitutional Condition ,
Vacated
Tax professionals are on the frontlines, responding to state, federal and international tax developments that significantly impact business objectives. California taxpayers face particularly unique challenges.
Join members...more
11/19/2019
/ Business Taxes ,
Continuing Legal Education ,
Events ,
False Claims Act (FCA) ,
Federal Taxes ,
Foreign Entities ,
Income Taxes ,
International Tax Issues ,
IRS ,
Local Taxes ,
Proposition 13 ,
Rebates ,
Sales Tax ,
State and Local Government ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Planning
On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more
11/7/2019
/ Anti-Abuse Rule ,
Foreign Corporations ,
Foreign Earned Income ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Large Business & International Division (LB&I) ,
Multinationals ,
New Guidance ,
Tax Cuts and Jobs Act ,
Tax Reform ,
Transition Tax
On September 28, 2019, the Treasury Inspector General for Tax Administration (TIGTA) issued a report titled Initial Compliance Results Warrant a More Data-Driven Approach to Campaign Issue Selection.
As the name of the...more
It took five years, but the Internal Revenue Service (IRS) has finally released some guidance on the taxation of cryptocurrencies! On October 9, 2019, the IRS released Revenue Ruling 2019-24 and several “frequently asked...more
The Large Business and International Division of the Internal Revenue Service (IRS) developed the Compliance Assurance Process (CAP) program to improve large corporate taxpayer compliance with US federal tax obligations...more
On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock...more
On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more
7/23/2019
/ Deferred Compensation ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
OVDP ,
S-Corporation ,
Section 457A ,
Tax Credits ,
Tax Planning ,
Tax Returns
The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or...more
The enactment of the Taxpayer First Act, H.R. 3151 (116th Cong.) (TFA) brings with it several changes to the procedures and operations of the Internal Revenue Service (IRS). The TFA touches on the following subjects...
...more
In Kearse v. Commissioner, T.C. Memo 2019-53, the Tax Court held the Internal Revenue Service (IRS) abused its discretion as part of the taxpayer’s Collection Due Process hearing (CDP hearing) because the Appeals officer...more