On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party transactions may appropriately determine
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.
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Weekly IRS Roundup June 24 – 28, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 24 – 28, 2019.
June 24, 2019: The IRS updated its frequently asked questions for Opportunity Zones page. In…
Taxpayer Advocate Service: Not Just for Low-Income Taxpayers
We recently wrote an article for the American Bar Association Section of Taxation, ABA Tax Times, on the Taxpayer Advocate Service (TAS), explaining what TAS does and how it can be utilized by all types of taxpayers. The article can…
Trust Wins Due Process Challenge to North Carolina State Income Tax
Last week, the US Supreme Court ruled that North Carolina may not tax a trust’s income when the trust’s only contact with the state is the in-state residence of discretionary beneficiaries. The Due Process Clause requires a minimum connection between…
Weekly IRS Roundup June 17 – 21, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 17 – 21, 2019.
June 18, 2019: The IRS issued a news release noting that it and the US…
Weekly IRS Roundup June 10 – 14, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10 – 14, 2019.
June 11, 2019: The IRS issued a news release noting that it and the US…
Weekly IRS Roundup June 3 – 7, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019.
June 4, 2019: The IRS issued a news release noting that it granted tax relief…
Is an Increase in LB&I Assertion of Penalties on the Horizon?
On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS Large Business & International (LB&I) Division.…
Weekly IRS Roundup May 27 – May 31, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 27 – May 31, 2019.
May 28, 2019: The IRS released Announcement 2019-05 listing recent disciplinary sanctions against attorneys,…
Taxpayers Should Prepare for the Next Penalty Battleground
The IRS is using a new tool from its arsenal to enforce compliance for tax refund and credit claims: the Internal Revenue Code Section 6676 penalty. Taxpayers and their advisers need to be aware of the mechanics of this penalty…