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By Carlyn S. McCaffrey, Brian Moore and McDermott Will & Emery on Mar 19, 2020
Posted In IRS Guidance, Uncategorized
On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS issued Notice 2020-17. The Notice declares that all taxpayers have been affected by the emergency...
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The Tax Impact of Recent Federal Actions Relating to COVID-19
By McDermott Will & Emery on Mar 18, 2020
Posted In IRS Guidance, Uncategorized
On March 13, 2020, President Trump signed a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”). By invoking the Stafford Act, the President provides the Internal Revenue Service (IRS) and US Department of the Treasury (the...
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When the IRS Says It’ll ‘Meet You in Paris’: Recent Trends & Developments in Outbound US Exchange-of-Information Techniques
By McDermott Will & Emery on Oct 3, 2019
Posted In IRS Guidance, Uncategorized
The Internal Revenue Service is looking for your international tax data—that is, if the IRS doesn’t already have it. With the rollout of the Foreign Account Tax Compliance Act (FATCA) and other automatic exchange-of-information (EOI) procedures, the IRS is now receiving—and making use of—a large amount of international tax information about US taxpayers. In an...
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Courtney Dunbar Jones and Emin Toro Confirmed to Tax Court
By McDermott Will & Emery on Aug 7, 2019
Posted In Court Procedure Matters, Trial Courts, Uncategorized
On August 5, 2019, the Senate confirmed Courtney Dunbar Jones and Emin Toro as nominees to the US Tax Court in a voice vote before leaving for August recess. Jones and Toro will now each serve a 15-year term. President Trump had initially nominated each candidate in 2018, but the Senate was not able to...
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Watch Your Mailbox: IRS Letters Warning of Cryptocurrency Non-Compliance on Their Way
By McDermott Will & Emery on Jul 30, 2019
Posted In IRS Guidance, Uncategorized
On July 26, 2019, the Internal Revenue Service (IRS) issued a press release informing the public that it is sending more than 10,000 letters to taxpayers with potentially unreported (or misreported) virtual currency transactions. The letters will inform them of the possible reporting requirements that may apply to these transactions and advise them of the...
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Law360: Myers May Make It Easier to Find Equitable Relief in Tax Court
By McDermott Will & Emery on Jul 18, 2019
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
Laura L. Gavioli, PC, recently wrote an article for Law360 on a US Court of Appeals for the District of Columbia Circuit’s decision that may provide an equitable avenue for hearing of late-filed petitions in US Tax Court. The Law360 article, “Myers May Make It Easier to Find Equitable Relief in Tax Court,” can be...
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Is an Increase in LB&I Assertion of Penalties on the Horizon?
By McDermott Will & Emery on Jun 5, 2019
Posted In IRS Appeals, IRS Audits, IRS Guidance, Uncategorized
On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS Large Business & International (LB&I) Division. The TIGTA report reviewed the results of closed LB&I examinations for the fiscal years 2015...
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Tax Court Announces Limited Entries of Appearance
By Kevin Spencer, McDermott Will & Emery and McDermott Will & Emery on May 29, 2019
Posted In Court Procedure Matters, Uncategorized
The concept of limited scope representation is not a new one in the legal arena. Rule 1.2(c) of the ABA Model Rules of Professional Conduct provides that “A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.” This rule has been broadly...
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IRS LB&I Sharpens Its Risk Analysis, Announces Large Corporate Compliance (LCC) Program
By McDermott Will & Emery on May 24, 2019
Posted In IRS Audits, IRS Guidance, Uncategorized
Last week, the IRS unveiled a major change in how it identifies its biggest and most complex large corporations for examination. The move is part of the IRS’s broader efforts toward “portfolio management”—maximizing and modernizing its resources to focus upon areas of highest tax compliance risk. The IRS’s Large Business and International Division (LB&I) has...
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Reasonable Cause for E-Filing Errors?
By McDermott Will & Emery on Mar 7, 2019
Posted In Court Procedure Matters, IRS Guidance, Tax Reform, Uncategorized
Tax return filing season is fast approaching, and taxpayers big and small are preparing to file their returns. A recent US Court of Appeals for the Fifth Circuit decision, Haynes v. United States, No. 17-50816 (5th Cir. Jan. 29, 2019), indicates that many of those taxpayers will face uncertainty if their returns are late due...
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