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By McDermott Will & Emery, Kevin Spencer and McDermott Will & Emery on Apr 16, 2019
Posted In Appellate Courts, Tax Reform, Tax Refunds, Trial Courts, Uncategorized
Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s holding in Borenstein that the court lacked jurisdiction to order a refund of an undisputed overpayment made by the taxpayer. The case, which...
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Weekly IRS Roundup March 18 – 22, 2019
By McDermott Will & Emery on Mar 25, 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 March 18 – 22, 2019. March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on proposed regulations on hybrid arrangements under Sections 245A and 267A of the code. March 19,...
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Weekly IRS Roundup February 25 – March 1, 2019
By McDermott Will & Emery on Mar 4, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05, announcing the interest rates for underpayments and overpayments under section 6621 of the Code, applicable for the calendar quarter beginning...
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Weekly IRS Roundup February 18 – 22, 2019
By McDermott Will & Emery on Feb 25, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online resources for answering taxpayer questions, in light of high call volume during the period following Presidents Day. February 19,...
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Weekly IRS Roundup February 11 – 15, 2019
By McDermott Will & Emery on Feb 19, 2019
Posted In IRS Guidance, Tax Reform, Tax Refunds, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 11 – 15, 2019. February 11, 2019: The IRS issued a news release promoting online resources for answering taxpayer questions, in anticipation of high call volume over the Presidents Day weekend. February 12, 2019:...
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Big Change for Witness Privilege in House Investigations
By Llewelyn Engel and McDermott Will & Emery on Feb 15, 2019
Posted In Court Procedure Matters, Privilege and Non-Disclosure, Uncategorized
On Jan. 25, 2019, U.S. House of Representatives Rules Committee Chairman James P. McGovern, D-Mass., issued regulations governing staff deposition authority in the 116th Congress, pursuant to his authority under H. Res. 6. In passing H. Res. 6, the newly empowered House Democratic majority drastically increased House committees’ investigative power by allowing committee staff to...
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IRS LB&I Division Announces Its New Year’s Resolutions
By McDermott Will & Emery, Kevin Spencer and McDermott Will & Emery on Feb 6, 2019
Posted In IRS Audits, IRS Guidance, Tax Reform, Uncategorized
Each New Year, many of us look back on the previous year’s activities, and determine what we want to accomplish in the coming year – lose weight, start exercising, read more tax articles, etc. The Internal Revenue Service (IRS) Large Business & International (LB&I) Division memorialized its New Year’s resolutions for 2019 in Publication 5319....
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Weekly IRS Roundup January 28 – February 1, 2019
By McDermott Will & Emery on Feb 4, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 28 – February 1, 2019. January 28, 2019: The IRS issued Revenue Ruling 2019-04, providing various prescribed rates for federal income tax purposes for February 2019. January 28, 2019: The IRS issued a news...
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Weekly IRS Roundup January 14 – 18, 2019
By McDermott Will & Emery on Jan 22, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 14 – 18, 2019. January 15, 2019: The IRS issued final regulations implementing the transition tax under section 965 of the Code, enacted as part of the Tax Cuts and Jobs Act. January 15,...
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Weekly IRS Roundup January 7 – 11, 2019
By McDermott Will & Emery on Jan 14, 2019
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 7 – 11, 2019. Tax news is very limited because of the government shutdown: January 7, 2019: The IRS issued a news release confirming that, despite the partial federal government shutdown, it will process...
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