McDermott Will & Emery
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Tax Reform Insight: Congress Offers a Glimmer of Hope for Taxpayers with Section 965 Transition Tax Overpayment
By McDermott Will & Emery on Dec 19, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Recently proposed legislation would provide taxpayers who made an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over eight years through installment payments the ability to claim a refund or credit of any overpayment with respect to such amounts. If enacted, taxpayers would be able to claim a refund or...
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Weekly IRS Roundup December 10 – 14, 2018
By McDermott Will & Emery on Dec 17, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 10 –14, 2018: December 10, 2018: The IRS issued Notice 2018-99, providing interim guidance on sections 274 and 512 of the Code, as amended by the Tax Cuts and Jobs Act, dealing with nondeductibile...
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In-Person IRS Appeals Conferences Are Here to Stay
By Kevin Spencer and McDermott Will & Emery on Dec 14, 2018
Posted In IRS Appeals, IRS Guidance, Uncategorized
On November 28, 2018, the IRS issued a memorandum to its Appeals division employees, providing guidance on how and where to conduct Appeals conferences with taxpayers. As we have previously reported, the IRS Appeals division has been in flux for the last several years constrained by limited resources, retiring Appeals Officers, and an ever-growing case...
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Tax Court Announces Adoption of Amendments to Rules of Practice and Procedure
By Kevin Spencer and McDermott Will & Emery on Dec 4, 2018
Posted In Court Procedure Matters, Trial Courts, Uncategorized
Back in April, we discussed possible changes to the Tax Court Rules of Practice and Procedure based on comments made at the Tax Court Judicial Conference in Chicago. On November 30, 2018, the Tax Court announced the adoption of amendments to its Rules in several areas. Certain amendments are discussed below. Payments to the Tax...
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Weekly IRS Roundup November 26 – 30, 2018
By McDermott Will & Emery on Dec 3, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 26 – 30, 2018: November 26, 2018: The IRS issued the proposed regulations under Code Section 163(j) regarding the limitations on business interest expense deductions after the enactment of the Tax Cuts and Jobs...
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Law360: A Look At Tax Code Section 199’s Last Stand
By Kevin Spencer and McDermott Will & Emery on Nov 7, 2018
Posted In Alternative Dispute Resolution, Court Procedure Matters, IRS Guidance, Settlements, Tax Reform, Trial Courts, Uncategorized
Andy Roberson, Kevin Spencer and Emily Mussio recently authored an article for Law360 entitled, “A Look At Tax Code Section 199’s Last Stand.” The article discusses the IRS’s contentious history in handling Code Section 199 and the taxpayers’ continued battle to claim the benefit – even after its recent repeal. Access the full article. Originally...
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Weekly IRS Roundup October 29 – November 2, 2018
By McDermott Will & Emery on Nov 5, 2018
Posted In IRS Audits, IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 29 – November 2, 2018: October 30, 2018: The IRS issued a notice of public hearing on November 28, 2018, regarding the proposed regulations the first-year additional depreciation deductions under section 168(k). October 30,...
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The LB&I Campaigns Keep Coming!
By Kevin Spencer and McDermott Will & Emery on Oct 31, 2018
Posted In IRS Audits, IRS Guidance, Uncategorized
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” The most recent announcement on October 30, 2018, identifies five new campaigns, which were identified through LB&I data analysis and suggestions from IRS employees. With the addition of these new campaigns, LB&I has now identified 50 campaigns...
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NTA Announces Date and Location for 4th International Conference on Taxpayer Rights
By McDermott Will & Emery on Oct 26, 2018
Posted In Uncategorized
The National Taxpayer Advocate recently announced that the 4th International Conference on Taxpayer Rights will be held May 23 – 24, 2019, in Minneapolis, Minnesota. The purpose of conference is to connect government officials, scholars and practitioners from around the world to explore how taxpayer rights globally serve as the foundation for effective tax administration....
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Weekly IRS Roundup October 8 – 12, 2018
By McDermott Will & Emery on Oct 15, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 8 – 12, 2018: October 8, 2018: IRS issued a special update in Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns, providing that transfer agreements under Prop. Reg. §...
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