News & Analysis as of November 15, 2024

Income Taxes › Internal Revenue Service › Attorney-Client Privilege

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

What to do if You Receive an IRS Audit Notification Letter 0724

Allen Barron, Inc. on 7/15/2024

What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

Vinson & Elkins LLP on 12/29/2022

The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more

What is a Kovel Accountant? A Deep Dive.

Freeman Law on 8/2/2021

Kovel Agreement - The Internal Revenue Service (IRS) has broad statutory authority to investigate and audit taxpayers. In many cases, the IRS attempts to fulfill this statutory authority through seeking communications made...more

The Federal Tax Law and Lawyers

Freeman Law on 12/8/2020

In many respects, operating a law firm is no different than any other business. Specifically, the law firm generates revenues through providing services to its clients and incurs various operating expenses throughout the...more

Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination

Jones Day on 2/21/2019

This video is the first in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage one - planning for and handling the IRS examination. He emphasizes the importance of...more

Wealth Management Update - October 2016

Proskauer Rose LLP on 10/1/2016

October Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more

Focus on Tax Controversy - December 2015

McDermott Will & Emery on 12/16/2015

IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court - In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more

"Cost-Efficient Alternatives for Document Production Gaining Traction"

Skadden, Arps, Slate, Meagher & Flom LLP on 10/2/2014

Tax controversies often involve voluminous document production and extensive privilege logs from multiple parties. The privilege issues can be complex and involve advice from multiple advisers potentially covering several...more

Focus on Tax Controversy - Summer 2014

McDermott Will & Emery on 6/24/2014

In This Issue: - Waiver of Privilege: Disturbing Trends - New Repair Regulations Affect All Taxpayers - Unclaimed Property – It Is Not a Tax, but It Can Feel Like One - Excerpt from Waiver of...more

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