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McDermott Named #1 Firm for Tax Thought Leadership


By on Mar 6, 2023
Posted In Uncategorized

We greatly appreciate our readers over the past year and are pleased to share that we were recently recognized as the #1 firm for tax thought leadership in the 2023 JD Supra Readers’ Choice Awards, which acknowledge top authors and firms for their thought leadership in key topics during all of last year. Partner and blog editor...

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Weekly IRS Roundup January 3 – January 6, 2023


By on Jan 9, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023. January 3, 2023: The IRS released Internal Revenue Bulletin 2023-1, which highlights the following: Revenue Procedure 2023-1: This contains the revised procedures for letter rulings and information letters...

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Weekly IRS Roundup December 5 – December 9, 2022


By on Dec 12, 2022
Posted In IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 5, 2022 – December 9, 2022. December 5, 2022: The IRS released Internal Revenue Bulletin 2022-49, which highlights the following: Revenue Procedure 2022-39: This revenue procedure obsoletes Revenue Procedure 94-69, 1994-2 C.B. 804, and...

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Weekly IRS Roundup March 8 – March 12, 2021


By on Mar 17, 2021
Posted In IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 8, 2021 – March 12, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. March 11, 2021: The IRS released Internal Revenue Bulletin 2021-11, dated March...

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Weekly IRS Roundup September 21 – September 25, 2020


By on Oct 2, 2020
Posted In IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 21, 2020 – September 25, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. September 21, 2020: The IRS released Announcement 2020-12 to detail information reporting requirements...

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IRS Issues Transition Tax Compliance Campaign


By , and on Nov 6, 2019
Posted In IRS Appeals, IRS Audits, IRS Guidance, Tax Reform, Uncategorized

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 that LB&I has announced since the initial 13 campaigns were identified in 2017, and is...

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Weekly IRS Roundup August 26 – 30, 2019


By on Sep 3, 2019
Posted In IRS Guidance, Uncategorized

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 to TD 9866 (i.e., the global intangible low-taxed income (GILTI) and Foreign Tax Credit Regulations...

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IRS Resumes Examinations of Stock Based Compensation in Cost Sharing Agreements


By , and on Aug 8, 2019
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized

On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock based compensation (SBC) in Cost Sharing Arrangements (CSAS). See here for IRS Notice of Withdrawal. The Directive was issued January 12, 2018, after the Tax Court’s...

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Weekly IRS Roundup May 6 – 10, 2019


By on May 13, 2019
Posted In Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue Procedure 75-50 in order to reflect technological advances. Revenue Procedure 75-50 provides guidelines to determine whether a private school...

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Weekly IRS Roundup April 15 – 19, 2019


By on Apr 22, 2019
Posted In IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15 – 19, 2019. April 16, 2019: The IRS issued Revenue Ruling 2019-12 providing monthly tables of prescribed rates under numerous Code sections, including the applicable federal rate for May. April 16, 2019: The...

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