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Subscribe to McDermott Will & Emery's PostsWeekly IRS Roundup September 24 – 28, 2018
By McDermott Will & Emery on Oct 1, 2018
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 September 24 – 28, 2018: September 25, 2018: The IRS announced a study regarding the active trade or business requirements under section 355(b) and stated that it is considering guidance on whether a business can...
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European Partner Joins Tax in the City® for Last Seattle Event of 2018
By McDermott Will & Emery on Sep 27, 2018
Posted In Uncategorized
On September 12, 2018, McDermott held the second Tax in the City® Seattle event this year and was pleased to welcome our partner Nina Siewert from our Frankfurt office to join US panelists Elizabeth Chao, Britt Haxton, Kristen Hazel, Sandra McGill and Diann Smith. The team’s key takeaways include: Taxation of the Digital Economy –...
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Weekly IRS Roundup September 17 – 21, 2018
By McDermott Will & Emery on Sep 24, 2018
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 September 17 – 21, 2018: September 17, 2018: The Treasury Inspector General for Tax Administration (TIGTA) released a report reviewing whether the IRS complied with legal and internal guidelines governing the seizure of property for...
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International News II 2018 | International Tax
By McDermott Will & Emery on Sep 12, 2018
Posted In Uncategorized
McDermott Will & Emery recently published Issue 2, 2018 of International News, which covers a range of legal developments of interest to those operating internationally. This issue focuses on the new rules for noncorporate US shareholders in relation to GILTI, the nuances of cryptocurrencies and the tax treatment of such, and highlights the most recent...
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A 360-Degree View: August & September 2018
By McDermott Will & Emery on Sep 11, 2018
Posted In Uncategorized
Wrapping Up August – and Looking Forward to September Top August Posts You Might Have Missed Alta Wind: Federal Circuit Reverses Trial Court and Kicks Case Back to Answer Primary Issue IRS Announces That CAP Will Continue IRS Issues Long-Awaited Initial Guidance under Section 162(m) Upcoming Tax Controversy Activities in September Our lawyers will present...
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Weekly IRS Roundup September 3 – 7, 2018
By McDermott Will & Emery on Sep 11, 2018
Posted In IRS Appeals, IRS Audits, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 3 – 7, 2018: September 4, 2018: The IRS reminded taxpayers that they have until September 28, 2018, to apply for the Offshore Voluntary Disclosure Program. September 5, 2018: In response to taxpayer inquiries,...
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Weekly IRS Roundup August 27 – 31, 2018
By McDermott Will & Emery on Sep 4, 2018
Posted In IRS Appeals, IRS Audits, IRS Guidance, Settlements, Uncategorized
Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 27 – 31, 2018: August 27, 2018: The IRS announced changes to its Compliance Assurance Process (CAP) program. We posted about the changes to CAP here. August 28, 2018: In Notice 2018-70, the IRS announced that it...
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Recent Developments in US Federal Income Tax Litigation
By McDermott Will & Emery on Aug 20, 2018
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
Summer is winding down and fall is approaching. Here are a few of the significant tax cases from the last few weeks. Tax Court YA Global Investments, LP v. Commissioner, 151 TC No. 2 (Aug. 8, 2018): The Tax Court held that withholding tax liability on effectively connected income of foreign partners is a partnership...
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Weekly IRS Roundup August 6 – 10, 2018
By McDermott Will & Emery on Aug 13, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our summary of significant IRS guidance and relevant tax matters for the week of August 6 – 10, 2018: August 6, 2018: The IRS and Treasury issued final regulations, which provide guidance regarding the new partnership audit rules. The regulations describe the procedure for designating a partnership representative and the partnership representative’s...
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Weekly IRS Roundup July 30 – August 3, 2018
By McDermott Will & Emery on Aug 7, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our weekly roundup for July 30 – August 3, 2018 on significant IRS guidance and relevant tax matters. July 31, 2018: In Notice 2018-58, the IRS stated that it intends to issue regulations clarifying new rules governing section 529 contributions. July 31, 2018: The IRS published three new frequently asked questions (Certifications...
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