McDermott Will & Emery
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Tax Reform Insight: IRS Doubles Down on Retention of 2017 Overpayments to Satisfy Future Section 965 Installment Payments
By David G. Noren, Lowell D. Yoder, Sandra P. McGill and McDermott Will & Emery on Jun 19, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
We previously discussed the Internal Revenue Service’s (IRS) surprising position that for taxpayers making an election under Internal Revenue Code (Code) Section 965(h) to pay the transition tax over 8 years through installment payments, any overpayments of 2017 tax liabilities cannot be used as credits for 2018 estimated tax payments or refunded, unless and until the overpayment...
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A Look at Treasury’s Recent Efforts to Reform Regulation
By McDermott Will & Emery on Jun 7, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
Just 10 days after his inauguration, President Trump signed Executive Order 13771, establishing the tenet of deregulation to be adopted by the Trump administration. Executive Order 13771 outlined the Trump administration’s vision for reducing regulation and controlling regulatory costs, and established a principle that for every one new regulation issued at least two prior regulations...
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Judge Foley Assumes The Reins as New Chief Judge of US Tax Court
By McDermott Will & Emery on Jun 1, 2018
Posted In Trial Courts, Uncategorized
Following up on our prior post, Judge Maurice B. Foley takes over today as Chief Judge of the US Tax Court (Tax Court). The term as Chief Judge spans two years and involves several statutory and administrative duties, including but not limited to the assignment of cases, appointment of Special Trial Judges, review of draft opinions,...
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Tax in the City® Seattle Proves to be the Largest Turnout to Date
By McDermott Will & Emery on May 31, 2018
Posted In Tax Reform, Trial Courts, Uncategorized
The second meeting of McDermott’s Tax in the City® initiative in Seattle was held on May 22, 2018 at the Amazon headquarters. McDermott established Tax in the City® in 2014 as a discussion and networking group for women in tax aimed to foster collaboration and mentorship, and to facilitate in-person connections and roundtable events around...
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IRS Implementation of Tax Reform Continues to Move Forward
By McDermott Will & Emery on May 24, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
The Internal Revenue Service (IRS) has been busy in recent months working on implementing the recent tax reform legislation. The latest announcement by the IRS focuses on the $10,000 cap on the amount of state and local taxes that can be deducted for federal income tax purposes. In a press release and release of guidance...
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LB&I Announces Six New Campaigns
By Kevin Spencer and McDermott Will & Emery on May 22, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
On May 21, 2018, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) announced the identification and selection of six new campaigns. These new campaigns follow the initial 13 campaigns announced on January 31, 2017, followed by 11 campaigns announced on November 3, 2017, and 5 campaigns announced on March 13, 2018.
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Treasury Releases Report on Regulatory Reform Accomplishments
By McDermott Will & Emery on Apr 30, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
On April 24, 2018, the US Department of the Treasury (Treasury) released a report (Report) outlining the efforts undertaken to-date by Treasury to implement the president’s regulatory reform agenda. The efforts have been in furtherance of President Trump’s Executive Order 13771 and Executive Order 13789 calling for a reduction in regulatory burdens and costs. The...
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Tax Court Judge Holmes Reappointed
By Kevin Spencer and McDermott Will & Emery on Apr 25, 2018
Posted In Court Procedure Matters, Trial Courts, Uncategorized
In a press release on April 24, 2018, the White House stated that President Trump has reappointed Tax Court Judge Mark Holmes for a second 15-year term. Judge Holmes was originally appointed by President George W. Bush on June 30, 2003, for a term ending June 29, 2018. Instead of seeking “senior status” on the...
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National Taxpayer Advocate Reminds Congress of IRS Deficiencies
By Kevin Spencer and McDermott Will & Emery on Apr 18, 2018
Posted In IRS Appeals, IRS Guidance, Uncategorized
On April 17, 2018, the Taxpayer Advocate, Nina E. Olson, testified before a Congressional Oversight Committee regarding on-going challenges to the administration of an efficient and effective tax system. Ms. Olson runs the Taxpayer Advocate Service (TAS), an independent office within the Internal Revenue Service (IRS). The Taxpayer Advocate is appointed by and reports directly to...
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Corporate Tax Newsletter: Are Changes Looming Over Tax Court’s Procedure Rules?
By Kevin Spencer and McDermott Will & Emery on Apr 16, 2018
Posted In Court Procedure Matters, Trial Courts, Uncategorized
Our recent post on potential changes to the Tax Court’s procedure rules has been republished in the Corporate Tax Newsletter – USA by The International Law Office. See here for the article.
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