In a series of frequently asked questions (FAQs) addressing the interaction of recently enacted net operating loss (NOL) carryback provisions and section 965, the IRS stated that taxpayers may not receive a refund of any section 965 tax payment unless
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
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Fifth Circuit Rules that Law Firm Clients’ Identities Are Not Privileged
In Taylor Lohmeyer Law Firm P.L.L.C. v. United States, No. 19-50506, the United States Court of Appeals for the Fifth Circuit held that a Texas-based estate and tax-planning law firm (Firm) could not invoke the attorney-client privilege against an…
Weekly IRS Roundup April 20 – April 24, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 20 – April 24, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
New Revenue Ruling 2020-8 Helps Taxpayers Seek COVID-19 Tax Refund Claims
Recently, in Revenue Ruling 2020-8, the Internal Revenue Service (IRS) announced that it was suspending Revenue Ruling 71-533, which had addressed the interaction of two Internal Revenue Code (IRC) provisions regarding limitations periods on refund claims, pending reconsideration of the…
IRS Flexes Its Administrative Summons Power in Recent Tax Case
The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain the information…
Weekly IRS Roundup April 13 – April 17, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 13 – April 17, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource…
IRS Guidance Signals More Stringent Scrutiny on Transfer Pricing Documentation
On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required under Internal Revenue Code (IRC) section 6662(e) and Treasury Regulations…
More Guidance on CARES Act Refund Claims
On April 8, 2020, the Internal Revenue Service (IRS) released a statement telling taxpayers that guidance would be forthcoming on refund claims related to the Coronavirus Aid, Relief and Economic Security Act, or the CARES Act. Consistent with that promise,…
CARES Act Update: IRS Provides Guidance to Partnerships to Take Advantage of Liquidity Benefits
On April 8, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-23 in response to the Coronavirus Aid, Relief and Economic Security (CARES) Act. Rev. Proc. 2020-23 eases restrictions on partnerships’ ability to file amended tax returns and issue…
Weekly IRS Roundup April 6 – 10, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 6 – 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page…