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.
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019.
September 16, 2019: The IRS issued a news release about time-limited settlement offers made to eligible…
The Large Business and International Division of the Internal Revenue Service (IRS) developed the Compliance Assurance Process (CAP) program to improve large corporate taxpayer compliance with US federal tax obligations through the use of real-time issue resolution tools and techniques.…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9 – 13, 2019.
September 9, 2019: The IRS released a revision to its Internal Revenue Manual that clarifies procedures…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019.
September 3, 2019: The IRS issued a notice in which it released the applicable amount…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019.
August 26, 2019: The IRS released a Treasury Decision in which it issued correcting amendments…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 19 – 23, 2019.
August 20, 2019: The IRS released a proposed regulation that provides corrections to proposed rules…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12 – 16, 2019.
August 12, 2019: The IRS issued a news release announcing that John Moriarty has been selected…
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 5 – 9, 2019.
August 5, 2019: The IRS issued a notice of withdrawal of directive LB&I-04-0118-005, which provided…
On August 5, 2019, the Senate confirmed Courtney Dunbar Jones and Emin Toro as nominees to the US Tax Court in a voice vote before leaving for August recess. Jones and Toro will now each serve a 15-year term. President…
