McDermott Will & Emery
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Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime
By Kevin Spencer, Jenny L. Johnson Ware and McDermott Will & Emery on May 28, 2021
Posted In Appellate Courts, Court Procedure Matters, IRS Audits, IRS Guidance, Trial Courts
In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime. CIC alleged that the IRS violated the Administrative Procedure Act (APA) when it issued Notice 2016-66 (Notice), deeming certain micro-captive insurance transactions...
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Eighth Circuit Holds the Mayo in Tax Regulation Invalidity Case
By Kevin Spencer and McDermott Will & Emery on May 17, 2021
Posted In Appellate Courts, Court Procedure Matters, Tax Reform, Trial Courts
In the latest tax regulation deference case, the Eighth Circuit provided guidance to taxpayers and tax practitioners on the “analytical path” to resolve the question of whether a tax regulation is a valid interpretation of the Internal Revenue Code. The court held that the regulation was invalid in part because it unreasonably added conditions to...
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IRS Extends Use of Digital Signatures for Certain Forms until End of 2021
By Kevin Spencer, Michael Bruno and McDermott Will & Emery on Apr 23, 2021
Posted In IRS Guidance
The list of Internal Revenue Service (IRS) forms that can be digitally signed continues to grow. On August 28, 2020, the IRS issued a memorandum indicating that it would accept the use of digital signatures on various IRS forms because of the restrictions involved with the COVID-19 pandemic. In September 2020, it announced the addition...
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Biden Spending Proposal Calls for 10% IRS Budget Increase
By Kevin Spencer, Brian Moore and McDermott Will & Emery on Apr 21, 2021
Posted In IRS Appeals, IRS Audits, IRS Guidance
The Biden Administration has requested a $1.2 billion increase in funding for the Internal Revenue Service (IRS) as part of its proposal for Fiscal Year 2022 (FY 2022) discretionary funding released in a letter from Office of Management and Budget Acting Director Shalanda Young on April 9, 2021. The additional funding would bring the IRS...
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IRS Issues Practice Unit on Section 965 Transition Tax
By Kevin Spencer and McDermott Will & Emery on Mar 24, 2021
Posted In IRS Audits, IRS Guidance, Tax Reform
One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section 965 as a campaign issue and is actively auditing taxpayers’ transition tax calculations and positions, along with other tax reform items. The stakes are...
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Weekly IRS Roundup March 1 – March 5, 2021
By McDermott Will & Emery on Mar 9, 2021
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 1, 2021 – March 5, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. March 1, 2021: The IRS issued Notice 21-20 providing guidance regarding the...
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Weekly IRS Roundup February 22 – February 26, 2021
By McDermott Will & Emery on Mar 2, 2021
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 22, 2021 – February 26, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. February 25, 2021: The IRS issued an alert warning taxpayers to refrain...
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Weekly IRS Roundup February 15 – February 19, 2021
By McDermott Will & Emery on Feb 24, 2021
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 15, 2021 – February 19, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. February 16, 2021: The IRS issued Revenue Ruling 21-05, which provides the...
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Weekly IRS Roundup February 8 – February 12, 2021
By McDermott Will & Emery on Feb 17, 2021
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 8, 2021 – February 12, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. On February 9, the Internal Revenue Service announced that Nancy Sieger would...
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Weekly IRS Roundup February 1 – February 5, 2021
By McDermott Will & Emery on Feb 8, 2021
Posted In IRS Guidance, Tax Reform
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 1, 2021 – February 5, 2021. Additionally, for continuing updates on the tax impact of COVID-19, please visit our resource page here. February 4, 2021: The IRS published Rev. Proc. 2021-15 providing a safe...
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