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McDermott Will & Emery partners with leaders around the world to fuel missions, knock down barriers and shape markets. Our team works seamlessly across practices, industries and more than 20 locations to deliver highly effective—and often unexpected—solutions that propel success. More than 1,200 lawyers strong, we bring our personal passion and legal prowess to bear in every matter for our clients and the people they serve.

Taxpayer Rights Around the World (Part 2)


By on Mar 24, 2017
Posted In Court Procedure Matters, IRS Guidance, Transfer Pricing Resource, Uncategorized

We previously posted on Day One of the 2nd International Conference on Taxpayer Rights in Vienna, Austria. Below, we summarize the panels and issues discussed on Day Two. Four panels were held on March 14: (1) Penalties and General Anti-Avoidance Rules; (2) The Role of Intergovernmental Actors in Furthering and Protecting Taxpayer Rights: A Conversation;...

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Taxpayer Rights Around the World (Part 1)


By on Mar 22, 2017
Posted In Court Procedure Matters, IRS Guidance, Transfer Pricing Resource, Uncategorized

On March 13 and 14, the 2nd International Conference on Taxpayer Rights was held in Vienna, Austria. More than 150 individuals from more than 40 countries attended the conference, which connects government official, scholars and practitioners from around the world to explore how taxpayer rights globally serve as the foundation for effective tax administration. This...

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Fast Track Settlement Now For SB/SE Taxpayers


By and on Mar 20, 2017
Posted In Alternative Dispute Resolution, IRS Appeals, IRS Audits, IRS Guidance, Settlements, Uncategorized

Today, the Internal Revenue Service (IRS) released Revenue Procedure 2017-25 extending the Fast Track Settlement (FTS) program to Small Business / Self Employed (SB/SE) taxpayers.  The IRS’s SB/SE group serves individuals filing Form 1040 (US Individual Income Tax Return), Schedules C, E, F or Form 2106 (Employee Business Expenses), and businesses with assets under $10...

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IRS Releases IPU Summarizing Foreign and Domestic Loss Impacts on FTCs


By on Mar 2, 2017
Posted In IRS Guidance, Uncategorized

On March 1, 2017, the Internal Revenue Service (IRS) released a new International Practice Unit (IPU) summarizing foreign and domestic loss impacts on foreign tax credits (FTC).  The IPU provides a summary of the law regarding worldwide taxation and FTC limitations, followed by explanations and analysis for IRS agents examining FTC issues.  As we have...

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Should Taxpayers File Amicus Briefs in Tax Court Cases?


By and on Feb 15, 2017
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized

Amicus–or “friend of the court”–briefs are not uncommon in Supreme Court and appellate court cases.  The purpose of an amicus brief is generally to provide assistance to the court by presenting additional arguments either in support or opposition of one of the litigant’s positions.  Amicus briefs should not rehash the same arguments presented by one...

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Busy Start to Trump Administration Bodes Major Changes Are on the Way


By and on Feb 14, 2017
Posted In IRS Guidance, Tax Reform, Uncategorized

In the first few weeks of the Trump administration, we have seen several indications that tax lawyers are going to be busy keeping up with the shifting sands of tax reform. We learned from an Executive Order released on January 30, 2017 that for every new regulation that will be issued, two regulations must be...

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Change in Leadership at DOJ Tax Division


By and on Feb 3, 2017
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized

The Department of Justice (DOJ) Tax Division is responsible for litigating tax refund claims brought in Federal district courts and the Court of Federal Claims and handling appeals from decisions of the United States Tax Court (the Chief Counsel’s office is responsible for Tax Court litigation).  Effective January 23, 2017, David A. Hubbert became the...

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Run for Cover—IRS Unveils Initial “Campaigns” for LB&I Audits


By , , and on Feb 1, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized

They’re here!  On January 31, 2017, the Internal Revenue Service (IRS) Large Business & International (LB&I) division released its much-anticipated announcement related to the identification and selection of campaigns.  The initial list identifies 13 compliance issues that LB&I is focused on and lists the specific practice area involved and the lead executive for each campaign. ...

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What to Expect During a Change of Administration


By , , and on Jan 25, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Uncategorized

With the inauguration of President Trump, and the accompanying change of administration, the American people have been promised great change in all areas of the federal government. One question we at McDermott have been frequently asked since the election is: what should a taxpayer expect from the Internal Revenue Service (IRS) and the Department of...

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National Taxpayer Advocate 2016 Report – IRS Appeals and Alternative Dispute Resolution


By and on Jan 24, 2017
Posted In Alternative Dispute Resolution, IRS Appeals, IRS Audits, Settlements, Uncategorized

In its annual report to the US Congress, the Taxpayer Advocate Service (TAS) had a lot to say about IRS Appeals and the (lack of) use of other alternative dispute resolution (ADR) techniques. In this post, we will highlight what the TAS had to say in this area. IRS Appeals Undoubtedly, one of the Internal...

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