McDermott Will & Emery
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Weekly IRS Roundup July 6 – July 10, 2020
By McDermott Will & Emery on Jul 14, 2020
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 6, 2020 – July 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. July 6, 2020: The IRS added new frequently asked questions on the...
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Weekly IRS Roundup June 29 – July 3, 2020
By McDermott Will & Emery on Jul 8, 2020
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 29, 2020 – July 3, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. June 29, 2020: The IRS issued a news release announcing that the...
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Weekly IRS Roundup June 22 – June 26, 2020
By McDermott Will & Emery on Jun 29, 2020
Posted In Court Procedure Matters, IRS Guidance, Settlements, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 22 – June 26, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. June 24, 2020: The IRS issued final regulations permitting a regulated investment company...
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Section 965 Statutes of Limitations for Partnerships
By Kevin Spencer and McDermott Will & Emery on Jun 29, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform
On May 26, 2020, the Internal Revenue Service (IRS) issued PMTA 2020-08 to provide guidance on the period of limitations for Internal Revenue Code (IRC) section 965, transition tax-related adjustments of partnerships. Typically, pursuant to IRC section 6501, the IRS has three years to assess a tax liability for a tax year. However, IRC section...
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IRS Targets Private Foundations That May Be Used by Wealthy Taxpayers in Tax Planning
By Kevin Spencer, Brian Moore and McDermott Will & Emery on Jun 26, 2020
Posted In IRS Audits, IRS Guidance, Tax Reform, Tax Refunds
In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the use of private foundations for tax planning. Ms. Tamera Ripperda, who is the commissioner of the Tax Exempt and Government Entities (TEGE) Division and previously served as the industry director for the Global...
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The Next Normal — Tax Responses to COVID-19
By McDermott Will & Emery on Jun 18, 2020
Posted In IRS Guidance
The coronavirus (COVID-19) pandemic has thrown our personal and professional lives into a constant state of change, as we deal with social distancing, e-learning, remote working, and Zoom. In this American Bar Association article, Andrew R. Roberson, a partner in US and International Tax at McDermott Will & Emery, describes how the constant change or...
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Tax Court Records Accessible Again
By Kevin Spencer and McDermott Will & Emery on Jun 11, 2020
Posted In Court Procedure Matters, IRS Guidance
When the US Tax Court (Tax Court) shut down in March, the public was unable to request copies of Tax Court records. That changed effective June 1, 2020, as non-parties may now call and request copies of court records which will then be sent via email. The cost for copy requests is $0.50 per page,...
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Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement
By Kevin Spencer, Brian Moore and McDermott Will & Emery on Jun 10, 2020
Posted In IRS Appeals, IRS Audits, IRS Guidance, Settlements, Trial Courts
A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency. In Howe v. Commissioner, T.C. Memo 2020-78, the Tax Court held that equitable estoppel did not bind the Commissioner to an...
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Weekly IRS Roundup June 1 – June 5, 2020
By McDermott Will & Emery on Jun 8, 2020
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 1 – June 5, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. June 2, 2020: The IRS reminded taxpayers who live and work abroad that they have until...
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Tax Court Holds IRS Chief Counsel Attorneys May Make Initial Penalty Determination
By Kevin Spencer, Brian Moore and McDermott Will & Emery on Jun 8, 2020
Posted In Appellate Courts, IRS Appeals, IRS Guidance
In general, section 6751 requires that a supervisor give written approval before penalties can be asserted against a taxpayer. In Koh v. Commissioner, T.C. Memo. 2020-77, authored by the US Tax Court’s (Tax Court) most recent addition—Judge Travis Greaves—the Tax Court affirmed that an attorney from Internal Revenue Service (IRS) Chief Counsel may be authorized to...
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