Evan Walters
Subscribe to Evan Walters's PostsEvan Walters focuses his practice on US and international taxation. He has experience across a wide range of issues involving corporate and partnership taxation. Read Evan Walter's full bio.
Weekly IRS Roundup July 31 – August 4, 2023
By Evan Walters on Aug 9, 2023
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 31, 2023 – August 4, 2023. July 31, 2023: The IRS released Revenue Ruling 2023-14, holding that a cash-method taxpayer who receives cryptocurrency units as validation rewards for staking cryptocurrency native to a proof-of-stake blockchain...
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Weekly IRS Roundup July 24 – July 28, 2023
By Evan Walters on Aug 1, 2023
Posted In IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 24, 2023 – July 28, 2023. July 24, 2023: The IRS released Internal Revenue Bulletin 2023-30, which includes proposed regulations that specify the methodology for constructing the corporate bond yield curve used to calculate present...
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IRS Criminal Investigation Division Is on the Hunt for Malta Pension Plan Participants and Promoters
By Daniel J. Bell, Steven Hadjilogiou, Kevin Spencer and Evan Walters on Jul 25, 2023
Posted In Uncategorized
There has been a growing trend of US taxpayers contributing non-cash assets, such as appreciated property, securities and cryptocurrency, into Maltese pension plans since the US-Malta Tax Treaty went into effect in 2011. These transactions were marketed to many US taxpayers as a way to cash in on their earnings without being subject to US federal taxation....
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Weekly IRS Roundup July 17 – July 21, 2023
By Evan Walters on Jul 24, 2023
Posted In IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 17, 2023 – July 21, 2023. July 17, 2023: The IRS released Internal Revenue Bulletin 2023-29, which includes Notices 2023-29, 2023-45 and 2023-47. These notices provide guidance to taxpayers seeking to qualify for the energy...
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Can the Government Sue for Tax Debts Outside Internal Revenue Code Procedures?
By Kevin Spencer, Edward L. Froelich and Evan Walters on Jul 21, 2023
Posted In Appellate Courts, Court Procedure Matters, Trial Courts
On June 1, 2023, in United States v. Liberty Global, Inc., the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies using a common law right of action, bypassing the usual statutory tax deficiency procedures outlined in the Internal...
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With the IRS, Mail Delivery Counts!
By Kevin Spencer and Evan Walters on Jun 29, 2023
Posted In Appellate Courts, Court Procedure Matters, Tax Refunds, Trial Courts
Over the years, case law has developed around when a mail delivery method is acceptable to prove that a tax filing was made. The US Court of Appeals for the Fourth Circuit’s recent decision in Pond v. United States[1] addresses how a taxpayer can prove delivery of a filing where the Internal Revenue Service (IRS)...
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IRS Continues Hiring Trend; Looks to Add over 400 Revenue Agents in the SB/SE Division
By Kevin Spencer, Evan Walters and McDermott Will & Emery on Jul 18, 2022
Posted In IRS Guidance
The Internal Revenue Service (IRS) recently announced that it will hire 470 new revenue agents into the Small Business Self Employed (SB/SE) division. This effort is part of a larger IRS staffing initiative, following a January 2022 announcement that the IRS plans to hire 200 lawyers to assist with litigation efforts, a March 2022 announcement...
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IRS Acknowledges Limitations on Use of Outside Contractors in Audits
By Kevin Spencer, Evan Walters and McDermott Will & Emery on Sep 10, 2021
Posted In IRS Audits, IRS Guidance, Trial Courts
Several years ago, it came to light that the Internal Revenue Service (IRS) had hired a law firm to assist with transfer pricing matters in an ongoing audit of a large corporate taxpayer. Contemporaneous with that hiring, the IRS issued temporary regulations providing that third-party contractors “may receive books, papers, records, or other data summoned...
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IRS Issues Annual “Dirty Dozen” List of Tax-Related Scams
By Kevin Spencer, Evan Walters and McDermott Will & Emery on Jul 1, 2021
Posted In IRS Guidance
Each year, the Internal Revenue Service (IRS) publishes a list of tax-related scams, which it calls the “Dirty Dozen.” This year, it provided a “Dirty Dozen” scam series warning taxpayers of such scams. In IR-2021-135 (June 28, 2021), the IRS rolled out its “Dirty Dozen” list for 2021, warning taxpayers to look out for 12...
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Taxpayers Should Prepare for the Next Penalty Battleground
By Evan Walters, Kevin Spencer and McDermott Will & Emery on May 31, 2019
Posted In IRS Audits, IRS Guidance, Tax Refunds, Uncategorized
The IRS is using a new tool from its arsenal to enforce compliance for tax refund and credit claims: the Internal Revenue Code Section 6676 penalty. Taxpayers and their advisers need to be aware of the mechanics of this penalty and how best to avoid it being sustained. Andrew R. Roberson, Kevin Spencer and Evan...
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