On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of several dozen compliance campaigns
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 October 28 – November 1, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019.
October 30, 2019: The IRS issued an Action on Decision in which it recommended…
Weekly IRS Roundup October 21 – 25, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 21 – 25, 2019.
October 21, 2019: The IRS issued a news release in which it announced the launch…
Government Questions the Benefits of IRS Audit Campaigns
On September 28, 2019, the Treasury Inspector General for Tax Administration (TIGTA) issued a report titled Initial Compliance Results Warrant a More Data-Driven Approach to Campaign Issue Selection.
As the name of the report describes, the TIGTA analyzed whether…
Weekly IRS Roundup October 14 – October 18, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019.
October 15, 2019: The IRS published a news release that discusses several tax benefits…
Weekly IRS Roundup October 7 – October 11, 2019
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 the six-month filing extension…
Finally the IRS Clarifies Its Position on Cryptocurrency
It took five years, but the Internal Revenue Service (IRS) has finally released some guidance on the taxation of cryptocurrencies! On October 9, 2019, the IRS released Revenue Ruling 2019-24 and several “frequently asked questions” (and answers) which deal…
Weekly IRS Roundup September 30 – October 4, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019.
September 30, 2019: The IRS published a draft of the tax year 2019: (i) Form…
When the IRS Says It’ll ‘Meet You in Paris’: Recent Trends & Developments in Outbound US Exchange-of-Information Techniques
The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now…
Weekly IRS Roundup September 23 – 27, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 23 – 27, 2019.
September 24, 2019: The IRS issued a notice that provides a safe harbor under which a…