McDermott Will & Emery
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New Chief Judge of US Tax Court
By Kevin Spencer and McDermott Will & Emery on Feb 27, 2018
Posted In Trial Courts, Uncategorized
On February 26, 2018, the US Tax Court announced that Judge Maurice B. Foley has been elected Chief Judge to serve a two-year term beginning June 1, 2018. Judge Foley will replace Chief Judge Paige Marvel. Judge Foley was appointed to the US Tax Court by President Clinton on April 9, 1995. He was reappointed...
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How Do You Interpret Terms Used in Statutes?
By McDermott Will & Emery on Feb 26, 2018
Posted In Appellate Courts, Uncategorized
Statutes in the Internal Revenue Code (Code), like statutes in other areas of the law, are filled with terms that invite differing interpretations. As a general rule, a statutory term should be given its normal and customary meaning. This might entail resorting to common dictionary definitions from Webster’s or Black’s Law Dictionary. It might also...
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Treasury and IRS Throw Out 298 Regulations and Amend 79 Others
By McDermott Will & Emery on Feb 13, 2018
Posted In IRS Guidance, Uncategorized
Following up on our prior posts here and here, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) have proposed to remove 298 regulations and amend 79 regulations. The Treasury’s and the IRS’s action is in response to Executive Order 13789 (April 21, 2017), which called on the Treasury and the IRS...
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Tax Court Addresses Statute of Limitations Issues in Rafizadeh v. Commissioner
By Elizabeth Chao and McDermott Will & Emery on Feb 12, 2018
Posted In Trial Courts, Uncategorized
Andrew Roberson and Elizabeth Chao recently wrote an article for Law360 entitled, “A Recent Tax Court View Of Statute Of Limitations Provisions.” The article discusses the Tax Court’s recent opinion in Rafizadeh v. Commissioner on statute of limitations for amounts reportable under Internal Revenue Code Section 6038D. Read the full coverage on Law360 here.
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IRS Releases Second Quarter Update to 2017-2018 Priority Guidance Plan
By Kevin Spencer and McDermott Will & Emery on Feb 9, 2018
Posted In IRS Guidance, Uncategorized
On February 7, 2018, the Department of the Treasury (Treasury) released its second quarter update to the 2017-2018 Priority Guidance Plan to identify tax issues it believes should be addressed through regulations, revenue rulings, revenue procedures, notices and other published administrative guidance. The Priority Guidance Plan contains projects the Treasury hopes to complete during the...
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A 360-Degree View: January and February 2018
By McDermott Will & Emery on Feb 8, 2018
Posted In Transfer Pricing Resource, Uncategorized
Wrapping Up January – and Looking Forward to February We invite you to view all of the topics we discussed over the last month and take a look at the upcoming tax controversy events where our lawyers will be speaking in February. Upcoming Tax Controversy Activities in February: February 15, 2018: David Noren will be...
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Treasury Moves Forward on Proposing Withdrawal of Regulations
By McDermott Will & Emery and McDermott Will & Emery on Jan 26, 2018
Posted In IRS Guidance, Uncategorized
As we previously discussed, the US Department of the Treasury (Treasury) announced a plan in October 2017 to repeal more than 200 regulations. The plan appears is moving forward based on remarks by Acting Chief Counsel William M. Paul earlier this week at the New York State Bar Association Section meeting that the Internal Revenue...
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Nominations Announced for Tax Court and IRS Commissioner
By K. Christy Vouri-Misso, McDermott Will & Emery and McDermott Will & Emery on Jan 24, 2018
Posted In Trial Courts, Uncategorized
On January 23, 2018, President Trump announced his intent to nominate Courtney Dunbar Jones to the US Tax Court. He previously nominated Elizabeth Copeland and Patrick Urda on August 3, 2017. Courtney Dunbar Jones is a senior attorney in the Tax-Exempt and Government Entities division in the Office of Chief Counsel of the Internal Revenue...
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Impact of Government Shutdown on IRS
By McDermott Will & Emery on Jan 22, 2018
Posted In IRS Guidance, Uncategorized
The Internal Revenue Service (IRS) has posted the following regarding the impact of the government shutdown on IRS employees: This message applies to all IRS employees. Due to the lapse in federal appropriations, the Internal Revenue Service began an IRS-wide furlough January 20, 2018. All IRS employees with the exception of those notified and deemed...
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IRS Releases Several Transfer Pricing Directives
By Lowell D. Yoder and McDermott Will & Emery on Jan 17, 2018
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division recently released several directives (LB&I Directives) geared toward transfer pricing. LB&I acknowledges that significant LB&I resources are devoted to transfer pricing issues, and such issues make up a substantial portion of the LB&I inventory. It appears that these directives are aimed at ensuring that...
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