TAX CONTROVERSY 360
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights

2020’s Key Tax Controversy Developments

By and on December 16, 2020
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, IRS Audits, IRS Guidance, Transfer Pricing Resource, Trial Courts

In the face of the pandemic and all the challenges that came with 2020, tax controversy marched on. In this article, we explore several important cases, including one of the most closely watched Supreme Court cases, CIC Services LLC v. Internal Revenue Service, which raises important questions regarding the scope of the Anti-Injunction Act and impacts the ability of taxpayers to engage in preenforcement challenges to regulations.

We also look into the latest updates in the transfer pricing area, changes to the Compliance Assurance Process, what to expect during the audit of a campaign issue and more.

Read the full article.

Tags: 3M Co. v. Commissioner, Altera Corp. v. Commissioner, Anti-Injunction Act, CAP program, CIC Services LLC v. Internal Revenue Service, Coca-Cola Co. v. Commissioner, Compliance Assurance Process, Facebook Inc. v. Commissioner, Internal Revenue Code Section 965, IRS Appeals Office, Medtronic Inc. v. Commissioner, Perrigo Co. v. United States, Revenue Procedure 94-69, SCOTUS, Subpart F regulations, Supreme Court, U.S. Court of Appeals for the Ninth Circuit, U.S. Court of Appeals for the Sixth Circuit, U.S. District Court for the Western District of Michigan, Western Digital Corp. v. Commissioner, Whirlpool Financial Corp. v. Commissioner
Kevin Spencer
Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Read Kevin Spencer's full bio.

McDermott Will & Emery
McDermott Will & Emery partners with leaders around the world to fuel missions, knock down barriers and shape markets. Our team works seamlessly across practices, industries and more than 20 locations to deliver highly effective—and often unexpected—solutions that propel success. More than 1,200 lawyers strong, we bring our personal passion and legal prowess to bear in every matter for our clients and the people they serve.

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