On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS
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.
Latest from Tax Controversy 360 - Page 5
US Tax Court Closed Until Further Notice
At 9:00 PM last night, the US Tax Court (Tax Court) issued a press release announcing that it was closing its building. As we previously discussed, the Tax Court previously closed the building to the public but still allowed…
The Tax Impact of Recent Federal Actions Relating to COVID-19
On March 13, 2020, President Trump signed a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”).
By invoking the Stafford Act,…
Tax Court Closes Building and Cancels More Trial Sessions
As the fallout from the coronavirus (COVID-19) continues, the US Tax Court (Tax Court) has cancelled additional trial sessions. As we previously discussed, the Tax Court last week cancelled all trial sessions for March 2020. Now, the Tax Court…
Weekly IRS Roundup March 9 – 13, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 9 – 13, 2020.
March 10, 2020: The IRS published a practice unit on how to compute the alternative…
Coronavirus (COVID-19) Results in Tax Court Trial Sessions Cancellations
The coronavirus (COVID-19) has now impacted the operations of the United States Tax Court (Tax Court). This morning, the Tax Court announced that after assessing all relevant factors relating to COVID-19, including travel and public health considerations, the trial sessions…
Weekly IRS Roundup March 2 – 6, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 2 – 6, 2020.
March 2, 2020: The US Treasury Department and the IRS released tax year 2018 statistics…
Weekly IRS Roundup February 24 – 28, 2020
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020.
February 24, 2020: The IRS released final instructions to Form 8978, Partner’s Additional Reporting Year…
New Tax Appointments
This has been a busy week in the tax appointments world, with the appointment of the new National Taxpayer Advocate (NTA), the reappointment of Chief Judge Foley as Chief Judge of the United States Tax Court (Tax Court), and the…
Supreme Court Tackles Tax-Related Cases
The United States Supreme Court has picked up the pace this week, already issuing eight regular opinions and four opinions relating to orders as of today. We discuss the tax-related items here.
In Rodriguez v. FDIC, the question was…