In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the use of private foundations for tax planning. Ms. Tamera Ripperda, who is the commissioner of the
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
Tax Controversy 360, published by McDermott Will & Emery, focuses on issues related to tax disputes and controversies involving the Internal Revenue Service and other tax authorities. The blog covers topics such as IRS enforcement actions, audit strategies, tax planning risks for high-net-worth individuals, regulatory updates, and procedural developments in tax litigation. It also addresses the impact of legislative changes and administrative guidance on tax controversy practice, including insights on private foundations, tax court procedures, and tax implications of current events like the COVID-19 pandemic. The content is aimed at tax professionals, advisors, and taxpayers navigating complex tax dispute environments.
Weekly IRS Roundup June 15 – June 20, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 15 – June 20, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
The Next Normal — Tax Responses to COVID-19
The coronavirus (COVID-19) pandemic has thrown our personal and professional lives into a constant state of change, as we deal with social distancing, e-learning, remote working, and Zoom. In this American Bar Association article, Andrew R. Roberson, a partner in…
Weekly IRS Roundup June 8 – June 12, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 8 – June 12, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
Tax Court Records Accessible Again
When the US Tax Court (Tax Court) shut down in March, the public was unable to request copies of Tax Court records. That changed effective June 1, 2020, as non-parties may now call and request copies of court records which…
Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement
A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency.
Weekly IRS Roundup June 1 – June 5, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
Tax Court Holds IRS Chief Counsel Attorneys May Make Initial Penalty Determination
In general, section 6751 requires that a supervisor give written approval before penalties can be asserted against a taxpayer. In Koh v. Commissioner, T.C. Memo. 2020-77, authored by the US Tax Court’s (Tax Court) most recent addition—Judge Travis Greaves—the…
Tax Court Zooms into Remote Proceedings
On May 29, 2020, the US Tax Court (Tax Court) announced that to accommodate continuing uncertainties relating to the COVID-19 pandemic, and until further notice, all court proceedings would be conducted remotely. The Tax Court also issued Administrative Order 2020-02…
Weekly IRS Roundup May 25 – May 29, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 25 – May 29, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…