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Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

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In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Holland & Hart LLP

5 Things to Know About the IRS Proposed Regulations for Supervisory Approval of Penalties

Holland & Hart LLP on

On April 11, 2023, the IRS issued proposed regulations concerning IRC § 6751(b). The statute requires that specific civil penalties must be personally approved (in writing) by the immediate supervisor of the individual making...more

McDermott Will & Emery

IRS Proposes New Regulations to Settle Supervisory Approval of Penalties Requirements

McDermott Will & Emery on

The Internal Revenue Service (IRS) has proposed regulations to clarify the rules regarding supervisory approval of federal civil tax penalties under IRC Section 6751(b). Since Chai v. Commissioner, there has been a...more

Polsinelli

The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation...

Polsinelli on

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement transactions as listed transactions – this...more

Latham & Watkins LLP

US Tax Court Voids Penalties Affecting Syndicated Conservation Easements; Treasury Reacts With Proposed Regulations

Latham & Watkins LLP on

The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

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