In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like they do to other federal agency...more
Tax returns and return information generally are protected from disclosure by Section 6103 of the Internal Revenue Code (Code), and unauthorized disclosures can result in penalties. Certain disclosures are permitted, but what...more
Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 30, 2021 – September 3, 2021... August 30, 2021: With September being National...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 19, 2021 – July 23, 2021. Additionally, for continuing updates on the tax impact of COVID-19,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020... August 24 2020: The IRS published a memorandum concerning...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 20, 2020 – July 24, 2020... July 20, 2020: The IRS published a news release on...more
The Taxpayer First Act (the “Act” or “TFA”) imposes new limits on the disclosure of US taxpayer tax information obtained on or after December 28, 2019. The Act is designed, among other things, to overhaul and modernize...more
Welcome to 2020! Although we have enjoyed the time off, we have been itching to get back into the swing of things. Since you have not seen Taxation & Representation in your inbox since the previous decade, we thought it was...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6 – January 10, 2020. January 6, 2020: The IRS issued a News Release confirming that the...more
The Taxpayer First Act adopted in the summer of 2019 includes the following provision that has an effective date of December 28, 2019...more
The Taxpayer First Act, enacted July 1, 2019, requires tax-exempt organizations to electronically file information returns and related forms. The new law affects tax-exempt organizations in tax years beginning after July 1,...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7 – October 11, 2019. October 7, 2019: The IRS announced that taxpayers who requested...more
On Oct. 8, the Treasury Department and the Internal Revenue Service (IRS) released the agency’s Priority Guidance Plan (PGP), which serves as a blueprint for forthcoming regulatory guidance from the agency between July 1,...more
On September 11, 2019, the Department of Labor announced that whistleblower retaliation complaints under the Taxpayer First Act (TFA) will be handled by the Occupational Safety and Health Administration (OSHA). ...more
President Trump signed the “Taxpayer First Act”, H.R. 3151, into law on July 1, 2019. The Taxpayer First Act may be one of the most significant “taxpayer rights” laws since the adoption of the Internal Revenue Service...more
• The Taxpayer First Act, which was signed into law by President Donald Trump on July 1, 2019, changed the requirements for tax-exempt organizations to require electronic filing of all returns in the Form 990 series and Form...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
Well, they did it. Despite lingering resentment between Democrats and Republicans after the passage of the Tax Cuts and Jobs Act (P.L.115-97), Congress was able to pass tax legislation that was overwhelmingly supported by...more
The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more