McDermott Will & Emery
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More Guidance on CARES Act Refund Claims
By Kevin Spencer and McDermott Will & Emery on Apr 14, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
On April 8, 2020, the Internal Revenue Service (IRS) released a statement telling taxpayers that guidance would be forthcoming on refund claims related to the Coronavirus Aid, Relief and Economic Security Act, or the CARES Act. Consistent with that promise, on April 13, 2020, the IRS issued guidance describing temporary procedures permitting the submission via...
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Weekly IRS Roundup April 6 – 10, 2020
By McDermott Will & Emery on Apr 13, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 6 – 10, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. April 8, 2020: The IRS announced that four LB&I campaigns related to agricultural chemicals...
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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19
By Brian Moore, Carlyn S. McCaffrey, McDermott Will & Emery and McDermott Will & Emery on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.
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CARES Act Refund Claim Guidance
By Kevin Spencer and McDermott Will & Emery on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
The Coronavirus Aid, Relief and Economic Security Act, or CARES Act, provides tax relief to taxpayers in certain situations. Some of these provisions may generate refunds for prior years, such as the relaxation of restrictions on the use of net operating losses (NOLs) and interest deductions as well as the retroactive availability of additional depreciation...
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IRS Failed to Prove Supervisory Approval For Penalty Based Upon Redacted Document
By Kevin Spencer, Le Chen and McDermott Will & Emery on Apr 8, 2020
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized
In a recent order in the The Cannon Corp. v. Commissioner, No. 12466-16, the US Tax Court (Tax Court) held that a redacted email from a revenue agent’s supervisor to the agent regarding a notice of deficiency was not sufficient to satisfy the approval requirement under Internal Revenue Code (IRC) section 6751(b) for the assertion...
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Weekly IRS Roundup March 30 – April 3, 2020
By McDermott Will & Emery on Apr 7, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 30 – April 3, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. March 30, 2020: Economic impact payments will be sent out over the next...
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Weekly IRS Roundup March 23 – 27, 2020
By McDermott Will & Emery on Mar 30, 2020
Posted In Court Procedure Matters, IRS Guidance, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 23 – 27, 2020. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. March 23, 2020: The US Tax Court cancelled trial sessions from May 4, 2020...
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No IDR Enforcement During COVID-19
By Kevin Spencer and McDermott Will & Emery on Mar 27, 2020
Posted In IRS Audits, IRS Guidance, Uncategorized
Yesterday, the Internal Revenue Service (IRS) announced in a memorandum to all Large Business & International (LB&I) division employees that it was suspending the normal Information Document Request (IDR) procedures. The letter suspends enforcement until July 15, 2020; however, LB&I managers will have the discretion to continue with the IDR enforcement process when in their...
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IRS to Temporarily Adjust Operations and Key Compliance Functions
By McDermott Will & Emery and McDermott Will & Emery on Mar 26, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized
On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges caused by the Coronavirus (COVID-19) pandemic. The initiative’s projected start date is April 1, 2020, and it...
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Taxpayer Victory in an IRC Section 199 Contract Manufacturing Case
By Brian Moore, Kevin Spencer and McDermott Will & Emery on Mar 24, 2020
Posted In Tax Refunds, Trial Courts, Uncategorized
Recently, the US Federal District Court for the Southern District of Iowa in Meredith Corp. v. United States, No. 4:17-cv-00385 (S.D. Iowa Mar. 20, 2020), held that a magazine publisher was entitled to refund of federal income tax based for the Internal Revenue Code (IRC) section 199 domestic production deduction based upon the printing services...
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