McDermott Will & Emery
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Second Circuit Weighs in on Tax Court’s Refund Jurisdiction
By McDermott Will & Emery, Kevin Spencer and McDermott Will & Emery on Apr 16, 2019
Posted In Appellate Courts, Tax Reform, Tax Refunds, Trial Courts, Uncategorized
Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s holding in Borenstein that the court lacked jurisdiction to order a refund of an undisputed overpayment made by the taxpayer. The case, which...
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Weekly IRS Roundup April 8 – 12, 2019
By McDermott Will & Emery on Apr 15, 2019
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 8 – 12, 2019. April 8, 2019: The IRS issued a news release warning taxpayers against rushing to file their returns and recommending they file for an extension if needed. April 9, 2019: The...
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Weekly IRS Roundup April 1 – 5, 2019
By McDermott Will & Emery on Apr 8, 2019
Posted In IRS Guidance, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1 – 5, 2019. April 2, 2019: The IRS issued a news release providing tips on payment options, penalty waivers, refunds and other filing related recommendations. April 3, 2019: The IRS issued a notice...
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Weekly IRS Roundup March 25 – 29, 2019
By McDermott Will & Emery on Apr 1, 2019
Posted In IRS Guidance, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25 – 29, 2019. March 25, 2019: The IRS issued Proposed Regulations under Section 301 of the code updating existing regulations to reflect changes made by the Technical and Miscellaneous Revenue Act of 1988....
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Taxpayers Already Seeking to Hold Treasury and IRS to Policy Statement
By Timothy S. Shuman and McDermott Will & Emery on Mar 20, 2019
Posted In IRS Guidance, Uncategorized
On March 5, 2019, the US Department of Treasury (Treasury) issued a policy statement on the tax regulatory process. We previously wrote an article for Law360 on the policy statement, which can be accessed here. In our article, we noted the disclaimer language in the policy statement that “is not intended to, and does not,...
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Weekly IRS Roundup March 11 – 15, 2019
By McDermott Will & Emery on Mar 18, 2019
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 4 – 8, 2019. March 11, 2019: The IRS cancelled a public hearing scheduled for March 14 on proposed regulations on changes to the foreign tax credit under Section 904 of the Code. March...
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Law360: Significant Changes in IRS Regulatory Process Ahead
By Timothy S. Shuman and McDermott Will & Emery on Mar 13, 2019
Posted In IRS Guidance, Uncategorized
We recently wrote an article for Law360 on the US Department of Treasury’s policy statement on the tax regulatory process. The Law360 article, “Significant Changes in IRS Regulatory Process Ahead,” can be accessed here.
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Weekly IRS Roundup March 4 – 8, 2019
By McDermott Will & Emery on Mar 11, 2019
Posted In IRS Guidance, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 4 – 8, 2019. March 4, 2019: The IRS issued proposed regulations under Section 250 of the Code for determining domestic corporations’ deductions for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI)....
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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...
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NTA Nina Olson Announces Upcoming Retirement
By Kevin Spencer and McDermott Will & Emery on Mar 1, 2019
Posted In IRS Guidance, Uncategorized
We have written in the past about the Taxpayer Advocate Service (TAS), which is an independent organization within the Internal Revenue Service (IRS) whose job is to ensure that every taxpayer is treated fairly and knows and understands taxpayer rights. For the past 18 years, Nina Olson has been the National Taxpayer Advocate (NTA) –...
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