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.
Ninth Circuit Interprets Summons Notice Rules Strictly Against IRS
By Evan Walters and McDermott Will & Emery on Mar 5, 2019
Posted In Appellate Courts, IRS Audits, IRS Guidance, Trial Courts, Uncategorized
The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek information from third parties. However, Internal Revenue Code (Code) Section 7602(c)(1) requires that the IRS provide “reasonable notice in advance...
Continue Reading
Tax Reform Insight: New Foreign Tax Credit Rules May Warrant Restructuring Foreign Branches
By Damon M. Lyon, Evan Walters and Lowell D. Yoder on Jun 27, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
The 2017 Tax Act added a separate foreign tax credit limitation category, or basket, for income earned in a foreign branch. As a result, certain US groups may be limited in their ability to use foreign income taxes paid or accrued by a foreign branch as a credit against their US federal income tax liability....
Continue Reading
