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By McDermott Will & Emery on Jul 31, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our weekly roundup for July 23 – 27, 2018 on significant IRS guidance and relevant tax matters. July 20, 2018: The IRS has updated its FAQ list for the Foreign Account Tax Compliance Act (FATCA) including new questions and answers regarding the IRS’s updated processing system and certifications for compliance. July 23,...
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Recent Developments in US Federal Income Tax Litigation
By McDermott Will & Emery on Jul 26, 2018
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
Presented below is a roundup of significant tax cases from the last few weeks. Tax Court Balocco v. Commissioner, T.C. Memo. 2018-108 (July 9, 2018): Judge Kerrigan found that personal aircraft maintenance expenses incurred by a “property flipper” were: (1) not ordinary or necessary expenses; and (2) were not properly substantiated by the taxpayer. Archer...
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Weekly IRS Roundup July 9 – 13, 2018
By McDermott Will & Emery on Jul 16, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our weekly roundup for July 9 – 13, 2018 on significant IRS matters. July 9, 2018: The IRS released Internal Revenue Bulletin No. 2018-28 including: Notice 2018-48 (lists the population census tracts designated as qualified opportunity zones); Notice 2018-59 (provides two methods for taxpayers to begin construction for the investment tax credit...
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Recent Developments in US Federal Income Tax Litigation
By McDermott Will & Emery on Jul 12, 2018
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
Presented below is a roundup of significant tax cases from the last month. Tax Court Van Lanes Recreation Center Corp. v. Commissioner, TC Memo. 2018-92 (June 26, 2018): Judge Paris determined the IRS abused its discretion when the agency revoked a prior favorable determination letter regarding the status of the taxpayer’s employee stock ownership plan...
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LB&I Announces Five New Campaigns
By McDermott Will & Emery and McDermott Will & Emery on Jul 10, 2018
Posted In IRS Guidance, Uncategorized
On July 2, 2018, the Internal Revenue Service (IRS) Large Business and International (LB&I) Division announced the identification and selection of five new campaigns. These new campaigns follow the initial 13 campaigns announced on January 31, 2017, followed by 11 campaigns announced on November 3, 2017, 5 campaigns announced on March 13, 2018, and six...
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Weekly IRS Roundup July 2 – 6, 2018
By McDermott Will & Emery on Jul 9, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our weekly roundup for July 2-6, 2018 on significant IRS matters. June 29, 2018: The IRS announced in IR-2018-146 that they plan to streamline the Form 1040 to shorten and simplify it for the 2019 tax filing season. The new approach would allow all taxpayers to use the same form. Draft of...
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Weekly IRS Roundup June 25 – 29, 2018
By McDermott Will & Emery on Jul 2, 2018
Posted In IRS Guidance, Uncategorized
Presented below is our weekly roundup for June 25 – 29, 2018 on significant IRS guidance and relevant tax matters. June 25, 2018: The IRS has scheduled a public hearing on the proposed regulations that would bar nongovernment attorneys from questioning summoned witnesses on behalf of the IRS for July 31. June 25, 2018: The...
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News of Wayfair Decision Breaks during Tax in the City® New York
By McDermott Will & Emery on Jun 29, 2018
Posted In Appellate Courts, State Controversy, Tax Reform, Uncategorized
The first New York meeting of McDermott’s Tax in the City® initiative in 2018 coincided with the June 21 issuance of the US Supreme Court’s (SCOTUS) highly anticipated Wayfair decision. Just before our meeting, SCOTUS issued its opinion determining that remote sellers that do not have a physical presence in a state can be required to collect...
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US Supreme Court Overrules Quill
By McDermott Will & Emery, Diann Smith, Eric Carstens and Stephen P. Kranz on Jun 26, 2018
Posted In Appellate Courts, State Controversy, Uncategorized
On June 21, 2018, the US Supreme Court issued its highly-anticipated decision in South Dakota v. Wayfair, Inc., et al., No. 17-494. The 5-4 opinion was authored by Justice Kennedy and concluded that the physical presence requirement established by the Court in its 1967 National Bellas Hess decision and reaffirmed in 1992 in Quill is...
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IRS Is “All Hands on Deck” to Provide Guidance Related to Tax Reform
By McDermott Will & Emery and McDermott Will & Emery on Jun 20, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
In the wake of tax reform, taxpayers and practitioners alike are anxious for guidance and clarification on how the new laws impact transactions and reporting positions. The Internal Revenue Service (IRS) has previously stated that implementing tax reform is its highest priority, but that issuing guidance on the entire bill would likely take a substantial...
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