Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Videocast: SALT Scoreboard – 2019 year in review
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Overview of IRS Appeals Judicial Approach & Culture Project (AJAC)
Jones Day Presents: Strategies for Dealing with the IRS: Alternative Dispute Resolution
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more
I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more
The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more
The IRS, Taxpayers, and Cryptocurrencies or virtual currencies - The Internal Revenue Service (“IRS”) issued its first guidance on cryptocurrencies— “virtual currencies''—in 2014, taking the position that crypto...more
Matt Hunsaker breaks down the latest state tax news including a discussion of tax arguments in a controversial civil war era statue removal case, the Texas Supreme Court's decision to hear Sirius XM's apportionment case, and...more
In this week's episode, Mike Semes joins Matt Hunsaker in the studio to discuss alternative apportionment and an unfortunate case coming out of Maryland....more
Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
The U.S. District Court for the District of Delaware held that corporate income tax liability attributable to transactions before the filing of a bankruptcy petition are nevertheless administrative expenses because the...more
The quarterly Eversheds Sutherland SALT Scoreboard tallies significant state and local tax litigation wins and losses. Twice each year, Eversheds Sutherland releases a videocast analyzing recent results. In this Bottom Line...more
The South Carolina Department of Revenue (SCDOR or DOR) recently issued a draft of long-awaiting guidance overhauling DOR’s administrative practices concerning disputed tax audits, refunds, license revocations, and other...more
We invite you to join us for our annual “Year in Review” Tax in the City® Chicago. We will discuss current tax issues including: • Judicial deference and potential impact on TCJA audits • Taxation of the digitalized...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more
The report highlights the recent changes to Ohio law requiring out-of-state sellers and marketplace facilitators to collect tax on sales into the state, as well as recent cases decided by the Ohio Board of Tax Appeals....more
In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more
This video is the second in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage two – the IRS Office of Appeals. He describes the office as having one mission – to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online...more
There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more