McDermott Will & Emery
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Special IRS Team Working to Identify Emerging “Abusive Transactions”
By Kevin Spencer and McDermott Will & Emery on Sep 7, 2022
Posted In IRS Audits, IRS Guidance
Earlier this year, the Internal Revenue Service (IRS) announced the creation of a new Joint Strategic Emerging Issues Team (JSEIT). The new initiative, announced at the New York University School of Professional Studies Tax Controversy Forum in June, brings together different agency divisions and organizations to identify and address emerging tax compliance issues. Various divisions,...
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Pro Bono as a Business Development Tool
By McDermott Will & Emery on Aug 31, 2022
Posted In Uncategorized
In this ABA Tax Times article, McDermott Partner Andrew Roberson discusses the benefits of taking on pro bono work and how it functions as a business development tool. “In my opinion, the motivation for doing pro bono work is to assist those in need who cannot afford our services. But if you need a little...
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IRS Announces Progress on Processing Tax Returns
By Kevin Spencer and McDermott Will & Emery on Aug 30, 2022
Posted In IRS Guidance, Tax Refunds
The phrase “it’s in the mail” is sometimes an excuse for one’s delinquency in filing tax returns. However, that is not necessarily the case for taxpayers who have submitted their individual tax returns during the COVID-19 pandemic. The impact of the pandemic on the Internal Revenue Service’s (IRS) ability to open mail and process returns...
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Weekly IRS Roundup August 22 – August 26, 2022
By McDermott Will & Emery on Aug 29, 2022
Posted In IRS Guidance, Tax Refunds
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 22, 2022 – August 26, 2022. August 22, 2022: The IRS released Internal Revenue Bulletin 2022-34, which highlights the following: Notice 2022-33. This guidance extends the deadlines for amending a retirement plan or individual...
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IRS Provides Tax Penalty Relief for Certain Late Filed Returns
By Kevin Spencer and McDermott Will & Emery on Aug 26, 2022
Posted In IRS Guidance, Tax Refunds
In Notice 2022-36, the Internal Revenue Service (IRS) announced relief for taxpayers who failed to file certain tax and information returns with respect to tax years 2019 and 2020. The relief, which will be automatic, is provided if taxpayers file the missing forms by September 30, 2022. Once filed, the penalties will be waived or...
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Tax Court Relaxes COVID-19 Protocols
By Kevin Spencer, Robert Levin and McDermott Will & Emery on Aug 25, 2022
Posted In Appellate Courts, Court Procedure Matters, Trial Courts
Courts have been relaxing their COVID-19 protocols over the past several months, and on August 23, 2022, the US Tax Court announced its latest position. In Administrative Order No. 2022-01, the Tax Court detailed new protocols for entry into the Washington, DC, courthouse, as well as in-person proceedings at all the locations in which it...
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Courts Outline Boundaries of the Anti-Injunction Act Post-CIC Services
By Kevin Spencer, Sarah M. Raben and McDermott Will & Emery on Aug 23, 2022
Posted In Appellate Courts, Court Procedure Matters, IRS Appeals, Trial Courts
Since the Supreme Court of the United States’ decision in CIC Servs., LLC v. IRS was issued in May 2021, courts have grappled with how to apply the Anti-Injunction Act (AIA) in other contexts. The US Court of Appeals for the Eleventh Circuit recently affirmed the dismissal of a lawsuit under the AIA in Hancock...
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IRS Appeals Retains Video Conference Option, Requests Public Input
By Sarah M. Raben and McDermott Will & Emery on Aug 22, 2022
Posted In IRS Appeals, IRS Audits, IRS Guidance
In 2017, we posted about the IRS Independent Office of Appeals’ (IRS Appeals) implementation of a face-to-face virtual option for taxpayers. Now, IRS Appeals wants suggestions from tax professionals on how to improve and enhance the video conferencing platform. IRS Appeals offers taxpayers conferences by telephone, video or in person. The COVID-19 pandemic triggered expanded...
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Supreme Court Requests Government Response to Whirlpool’s Petition
By McDermott Will & Emery on Aug 19, 2022
Posted In Appellate Courts, Court Procedure Matters, Trial Courts
We previously discussed the petition for writ of certiorari that was filed in the Supreme Court of the United States by Whirlpool Financial Corporation & Consolidated Subsidiaries and Whirlpool International Holdings S.a.r.l. & Consolidated Subsidiaries (collectively, Whirlpool); the amici briefs filed by The National Association of Manufacturers, the Silicon Valley Tax Directors Group, and three of the...
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It’s Official: President Biden Signs the Inflation Reduction Act into Law, IRS to Receive Increased Funding
By Kevin Spencer and McDermott Will & Emery on Aug 17, 2022
Posted In IRS Audits, IRS Guidance, Tax Reform
On August 16, 2022, US President Joe Biden signed into law the Inflation Reduction Act of 2022 (Act). A press release from the White House touts the Act as one that will “lower the costs for families, combat the climate crisis, reduce the deficit, and finally ask for the largest corporations to pay their fair...
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