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Rivkin Radler LLP

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

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Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

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The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, March 21, 2023

Senators Renew Efforts to Reverse R&D Tax Modification. Last Friday, a bipartisan coalition of 12 senators introduced the American Innovation and Jobs Act to increase incentives for businesses that invest in domestic research...more

Littler

Treasury Department’s Greenbook Discusses Tax Treatment of On-Demand Pay

Littler on

The U.S. Department of the Treasury has released a document to explain the revenue proposals included in President Biden’s FY 2023 proposed Budget.  For the second consecutive year, the General Explanations of the...more

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

Polsinelli on

Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more

Brownstein Hyatt Farber Schreck

The IRS, the President's Fiscal Year 2023 Budget, and the 2022 Filing Season

On Thursday, April 7, the Senate Finance Committee held a hearing entitled, “The IRS, the President's Fiscal Year 2023 Budget, and the 2022 Filing Season,” during which Internal Revenue Service (IRS) Commissioner Charles...more

Proskauer Rose LLP

Partnership-Level Tax Under New Audit Rules

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The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017. Under the current partnership...more

Morgan Lewis

New Legislation Makes Sweeping Changes Impacting All Partnerships

Morgan Lewis on

All partnerships will be audited at the entity level unless they have 100 or fewer partners AND no partnerships as direct partners. The two-year budget plan passed by Congress on October 30, 2015, and expected to be...more

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