TAX CONTROVERSY 360
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
taxpayers
Subscribe to taxpayers's Posts

Weekly IRS Roundup February 19 – February 23, 2024

by , and | Feb 29, 2024 | , , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 19, 2024 – February 23, 2024.

February 20, 2024: The IRS published Announcement 2024-12, which revokes tax-exempt status for the Chicago Cannabis Alliance and Keeping My Kids Inc.

February 20, 2024: The IRS reminded farmers and fishers who chose to forgo making estimated tax payments by January that they must generally file their 2023 federal income tax return and pay all taxes by March 1, 2024, to avoid estimated tax penalties.

February 20, 2024: The IRS reminded businesses to review their Employee Retention Credit eligibility because there’s limited time to voluntarily resolve incorrect claims and avoid issues, such as penalties and interest.

February 21, 2024: The IRS announced plans to begin dozens of audits on business aircraft involving personal use, focusing specifically on aircraft usage by large corporations, large partnerships and high-income taxpayers.

February 21, 2024: The IRS announced that interest rates for overpayments and underpayments will remain the same for the calendar quarter beginning April 1, 2024. Interest rates are provided in Revenue Ruling 2024-6.

February 21, 2024: The IRS reminded military personnel that they have several options to file their federal tax returns for free, including the US Department of Defense’s MilTax and the IRS Free File program.

February 21, 2024: The IRS announced the beginning of its 2024 Tax Time Guide series, which provides new and updated resources to help taxpayers file an accurate tax return.

February 22, 2024: The IRS warned tax professionals about a recurring scheme in which scammers pose as tax software providers and email tax professionals with requests to provide Electronic Filing Identification Number information via fax.

February 22, 2024: The IRS announced that applications for the 2025 Taxpayer Advocacy Panel (TAP) are now being accepted to fill vacancies in 29 states and territories. TAP submits recommendations to the IRS to help improve satisfaction with IRS services, products and procedures.

February 23, 2024: The IRS announced that the replacement of lead service lines under various governmental programs do not result in income to the residential property owners under Internal Revenue Code § 61.

February 23, 2024: The IRS issued frequently asked questions related to the US Department of Agriculture’s (USDA) Discrimination Financial Assistance Program, which provides financial assistance to farmers, ranchers and forest landowners who experienced discrimination by the USDA in farm lending prior to 2021.

February 23, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).



read more

Weekly IRS Roundup February 12 – February 16, 2024

by , and | Feb 21, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 12, 2024 – February 16, 2024.

February 12, 2024: The IRS released Internal Revenue Bulletin 2024-7, which includes the following:

  • Revenue Ruling 2024-5, which provides that if one or more of a state’s allocations of housing credit dollar amounts under § 305 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 to qualified disaster zones in 2021 or 2022 are returned after 2022, then the returned housing credit dollar amounts are not restricted to projects located in qualified disaster zones.
  • Announcement 2024-7, which corrects Revenue Procedure 2024-5 by providing initially omitted effective dates for changes to the user fees that apply to certain requests for advance approvals.
  • Announcement 2024-8, which revokes tax-exempt status for the Altruistic United Humanity Association.
  • Announcement 2024-9, which revokes tax-exempt status for the West Los Angeles Obedience Training Club Inc.
  • Notice 2024-20, which advises that forthcoming proposed regulations will set forth (i) requirements for qualifying as an eligible census tract for purposes of the alternative fuel vehicle refueling property credit under § 30C of the Internal Revenue Code (Code) and (ii) guidance as to how taxpayers can verify that property satisfies the geographic requirements of Code § 30C.
  • Notice 2024-23, which provides special relief under Code § 529 for certain rollovers to or from Maryland Prepaid College Trust (MPCT) accounts. Due to accounting discrepancies and administrative issues, access to MPCT interest earnings was frozen in April 2022 and restored July 2023. Due to the freeze, many taxpayers executed a qualified rollover out of MPCT accounts. Notice 2024-23 permits taxpayers to transfer funds back into an MPCT account in a qualified rollover even though the transfer of funds out of the MPCT account may have occurred within the past 12 months.

February 12, 2024: The IRS announced that Jim Lee, chief of IRS Criminal Investigation, will retire effective April 6, 2024.

February 12, 2024: The IRS issued Revenue Procedure 2024-14, which provides indexing adjustments for applicable dollar amounts used to calculate the employer shared responsibility payments under § 4980H(a) and (b)(1) of the Code.

February 12, 2024: The IRS reminded senior taxpayers of free tax filing options, including the programs Tax Counseling for the Elderly, Volunteer Income Tax Assistance and IRS Free File.

February 13, 2024: The IRS highlighted seven suspicious signs that an Employee Retention Credit claim may be questionable and could signal future IRS problems to help small businesses that may need to resolve incorrect claims.

February 13, 2024: The IRS alerted tax professionals to watch out for a “new client” scam, which is an email scheme (in which cybercriminals pose as potential clients) that peaks during the busy tax filing season.

[...]

Continue Reading


read more

Weekly IRS Roundup February 5 – February 9, 2024

by , and | Feb 13, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 5, 2024 – February 9, 2024.

February 5, 2024: The IRS released Internal Revenue Bulletin 2024-5, which includes the following:

  • Announcement 2024-4, which clarifies that until the IRS issues new final regulations under Internal Revenue Code (Code) Section 6050I implementing the Infrastructure Investment and Jobs Act, at this time, digital assets are not required to be included when determining whether cash received in a single transaction (or two or more related transactions) has a value exceeding the $10,000 reporting threshold.
  • Notice 2024-21, which provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2).
  • Notice 2024-22, which provides initial guidance on the anti-abuse rules under Code Section 402A(e)(12) to assist in the implementation of the SECURE 2.0 Act of 2022’s Section 127 provisions.
  • Final regulations, which provide guidance on changes made by the Pension Protection Act of 2006 to the prescribed interest rate and mortality table and other guidance, including rules for the treatment of preretirement mortality discounts and Social Security-level income options.
  • Revenue Ruling 2024-3, which provides the February 2024 applicable federal rates.

February 5, 2024: The IRS announced that individuals and businesses in parts of Maine affected by severe storms and flooding that began on December 17, 2023, now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments.

February 6, 2024: The IRS revised frequently asked questions for Form 1099-K, Payment Card and Third Party Network Transactions, providing more general information for taxpayers, including common situations, along with clarity as to which organizations should submit Forms 1099-K.

February 6, 2024: The IRS issued Revenue Procedure 2024-13, which provides two tables of limitations on depreciation deductions for owners of passenger automobiles placed in service during calendar year 2024 and a table of dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2024.

February 6, 2024: The IRS reminded taxpayers that through new elective payment and transfer options, applicable businesses; tax-exempt organizations; or entities such as state, local, and tribal governments can take advantage of certain tax credits and apply these options to certain clean energy and manufacturing credits. Eligible taxpayers can register using the IRA/CHIPS Pre-Filing Registration Tool.

February 7, 2024: The IRS issued Revenue Procedure 2024-12, which offers a temporary extension for providing certain seller reports under Code Sections 25E and 30D.

February 7, 2024: The IRS launched a new page on IRS.gov that explains the Employer-Provided Childcare Credit, which offers employers a tax credit of up [...]

Continue Reading



read more

Weekly IRS Roundup January 22 – January 26, 2024

by , and | Jan 30, 2024 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 22, 2024 – January 26, 2024.

January 22, 2024: The IRS released Internal Revenue Bulletin 2024-4, which includes Revenue Procedure 2024-8. This revenue procedure lists qualified census tracts used to determine income limits for targeted area residences for purposes of Internal Revenue Code (Code) § 143(a), dealing with qualified mortgage bonds, and Code § 25(c), dealing with mortgage credit certificates.

January 22, 2024: The IRS announced that individuals and businesses in parts of Connecticut affected by severe storms, flooding and a potential dam breach that began on January 10 now have until June 17, 2024, to file various federal individual and business tax returns and make tax payments.

January 22, 2024: The IRS reminded taxpayers that they must disclose whether they received or disposed of digital assets, such as cryptocurrency, on their 2023 personal income tax returns.

January 22, 2024: The IRS announced that IRS Free File is now available for the 2024 filing season. IRS Free File is generally available to taxpayers with adjusted gross income of $79,000 or less. Additional information can be accessed here.

January 23, 2024: The IRS announced that work is underway on the Simple Notice Initiative, which will review and redesign various IRS notices. The IRS intends to focus first on the notices that are most commonly sent to individual taxpayers.

January 23, 2024: The IRS published a Request for Information from the US Department of the Treasury, Employee Benefits Security Administration, US Department of Labor, and Pension Benefit Guaranty Corporation following the directive provided under the SECURE 2.0 Act of 2022 to review the existing reporting and disclosure requirements for retirement plans. Comments are due by April 22, 2024, and each agency will be required to report to US Congress on December 29, 2025. Reports will offer recommendations for simplifying, standardizing and improving reporting and disclosure requirements.

January 25, 2024: The IRS issued Notice 2024-23, which provides special relief under Code § 529 for certain rollovers to or from Maryland Prepaid College Trust (MPCT) accounts. Due to accounting discrepancies and administrative issues, access to MPCT interest earnings was frozen in April 2022 and restored in July 2023. As a result of the freeze, many taxpayers executed a qualified rollover out of MPCT accounts. Notice 2024-23 permits taxpayers to transfer funds back into an MPCT account in a qualified rollover even though the transfer of funds out of the MPCT account may have occurred within 12 months of the transfer back into an MPCT account.

January 26, 2024: In the spirit of the IRS’s annual Earned Income Tax Credit Awareness Day outreach campaign, the IRS posted information on the Earned Income Tax Credit to help educate low- to middle-income taxpayers who may be eligible to [...]

Continue Reading



read more

Weekly IRS Roundup January 15 – January 19, 2024

by , and | Jan 23, 2024 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024.

January 16, 2024: The IRS released Internal Revenue Bulletin 2024-3, which includes the following:

  • Notice 2024-10, which provides guidance on the corporate alternative minimum tax, including rules for determining the “adjusted financial statement income” of a US shareholder when a controlled foreign corporation pays a dividend and modifications to Notice 2023-64.
  • Proposed regulations, which provide guidance on the new Internal Revenue Code (Code) Section 45X advanced manufacturing production credit established by the Inflation Reduction Act of 2022 (IRA). This credit is intended to incentivize domestic production of certain green energy components.
  • Final regulations regarding penalty protections for de minimis errors on information returns and payee statements.

January 16, 2024: The IRS released transitional guidance under Code Section 60501 on reporting transactions involving the receipt of digital assets and clarified that at this time, digital assets are not required to be included when determining whether cash received in a single transaction (or two or more related transactions) meets the reporting threshold.

January 16, 2024: The IRS issued Revenue Ruling 2024-3, which provides the February 2024 applicable federal rates.

January 16, 2024: The IRS reminded taxpayers of their rights under the Taxpayer Bill of Rights, which includes 10 rights all taxpayers have any time they interact with the IRS. Those rights include privacy, confidentiality and the right to appeal an IRS decision in an independent forum.

January 17, 2024: The IRS announced the appointment of 12 new members to the Internal Revenue Service Advisory Council, a public forum that provides the IRS and agency leaders with feedback, observations and recommendations related to tax administration.

January 18, 2024: The IRS reached a major milestone in the implementation of key provisions in the IRA as more than 1,000 projects have now been registered through the new IRS Energy Credits Online tool.

January 18, 2024: The IRS alerted a limited group of tax-exempt organizations subject to unrelated business income tax that they will not be able to electronically file Form 990-T, Exempt Organization Business Income Tax Return, or Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations, until March 17, 2024.

January 19, 2024: The IRS issued Notice 2024-20, which provides guidance on the qualified alternative fuel vehicle refueling property credit under Code Section 30C. The IRS intends to issue additional guidance via proposed regulations.

January 19, 2024: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).



read more

Issues With the IRS? Here’s Why More Taxpayers Should Enlist the Help of the Taxpayer Advocate Service

by and | Jan 12, 2024 |

The Taxpayer Advocate Service (TAS) recently released its annual report to US Congress. The report highlights the TAS’s accomplishments in 2023 and its continued areas of focus and concern in the new year. While the report is an interesting read, in this article we discuss why it’s beneficial for taxpayers to have the TAS involved in their cases.

Created in 1996 by Congress, the TAS is an independent agency within the Internal Revenue Service (IRS). Its mission is to assist taxpayers with systematic issues involving the IRS. For example, suppose you are owed a refund and have been waiting to receive the check for two years now. Or perhaps you changed the name of your business, and the IRS keeps rejecting your returns because the name in their system does not match the new name because the name change has not been processed yet by the IRS. The TAS can typically help in these specific examples and in other similar IRS snafus.

To start the process, file Form 911 with your local TAS office. We suggest providing a comprehensive explanation of the issue you are facing and the steps you have taken to try and fix it in your Form 911. This will help the TAS advocate assigned to your case with getting you a solution quicker.

Practice Point: The TAS is not only for individual taxpayers. We have sought their assistance for all sorts of taxpayers, including large multinational public companies. We cannot emphasize enough how much faster it is to resolve an IRS issue with the help of the TAS rather than calling the general IRS service phone number or writing countless letters to the IRS.



read more

Weekly IRS Roundup October 23 – October 27, 2023

by | Oct 30, 2023 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 23, 2023 – October 27, 2023.

October 23, 2023: The IRS is recruiting volunteers for the Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) programs. VITA and TCE participants prepare millions of tax returns each year for low- to moderate-income taxpayers at no cost. No experience is necessary to volunteer. Volunteers will have the option to participate both in-person and via virtual sites. To learn more about becoming a VITA or TCE volunteer, visit IRS Tax Volunteers.

October 23, 2023: The IRS warned taxpayers to be wary of criminals falsely posing as legitimate charities to solicit donations. Donors can use the Tax-Exempt Organization Search tool on IRS.gov to find or verify legitimate charities.

October 23, 2023: The IRS released Internal Revenue Bulletin 2023-43, which includes the following:

  • Final regulations and proposed regulations that reduce the user fee to apply for or renew a preparer tax identification number (PTIN) from $21 to $11 (plus an amount payable directly to a third-party contractor).
  • Revenue Procedure 2023-28 provides guidelines for the development, printing and approval of 2023 substitute tax forms.
  • Proposed regulations that would provide guidance on §§ 30D(g) and 25E(f), including guidance involving:
    • Elections to transfer new and previously owned clean vehicle credits
    • Dealer qualifications for becoming an eligible entity that can receive advance payments of new and previously owned clean vehicle credits
    • Credit recapture.
  • Revenue Procedure 2023-33 sets forth the procedures for transferring new and previously owned clean vehicle credits from a taxpayer to an eligible entity under §§ 30D(g) and 25E(f), including procedures for dealer registration with the IRS, procedures for the suspension and revocation of said registration and the establishment of an advance payments program to registered dealers. This revenue procedure also provides guidance on the submission of seller reports and reports by qualified manufacturers.

October 24, 2023: The IRS reminded tax return preparers to renew their PTINs ahead of the upcoming tax filing season. Information to begin the online renewal process can be accessed here. Failure to have and to use a valid PTIN may result in penalties.

October 25, 2023: The IRS published Tax Tip 2023-118, which notes that tax professionals can use Tax Pro Accounts to send powers of attorney and tax information authorization requests directly to a client’s individual IRS Online Account.

October 25, 2023: The deadline to comment on proposed regulations involving information reporting, backup withholding and the determination of amount realized and basis for digital assets sales was extended from October 30, 2023, to November 13, 2023.

October 26, 2023: The IRS encouraged employers to electronically [...]

Continue Reading



read more

Weekly IRS Roundup October 16 – October 20, 2023

by | Oct 23, 2023 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 16, 2023 – October 20, 2023.

October 16, 2023: The IRS published Revenue Ruling 2023-20, which provides the November 2023 applicable federal rates.

October 16, 2023: The IRS announced that the deadline for 2022 income tax returns and payments for most California taxpayers has been postponed again until November 16, 2023. Because of natural disasters last winter, spring due dates were previously postponed to October 16, 2023. The list of localities eligible for the extension are available here.

October 16, 2023: Tax professionals can now access 18 self-study seminars that satisfy continuing education requirements for the federal tax law and ethics categories. The seminars can be accessed at Nationwide Tax Forums Online for a fee of $29 per seminar.

October 16, 2023: The IRS announced that it recently awarded $51 million in Tax Counseling for the Elderly and Volunteer Income Tax Assistance grants to organizations that provide free federal tax return preparation services.

October 16, 2023: The IRS released Internal Revenue Bulletin 2023-42, which includes the following:

  • Notice 2023-65 provides guidance on the energy efficient home credit under Internal Revenue Code (Code) § 45L. It addresses who is eligible for the credit, how to determine the applicable amount of the credit, energy saving requirements, certification requirements and substantiation requirements.
  • Notice 2023-67 gives farmers and ranchers who were impacted by drought an extra year to replace livestock from forced sales and defer gains under Code § 1033(e).
  • Notice 2023-69 provides that any cash donations employers make to charitable organizations that provide relief to victims of the wildfires in Hawaii in exchange for sick, vacation, or personal leave that their employees forgo will not be treated as compensation. The notice also provides that these employees will not be treated as receiving the value of the leave as income and cannot claim a deduction for the leave that they donated to their employer. Employers may deduct these cash payments as a business expense or a charitable contribution deduction if the employer otherwise meets the respective requirements of the applicable sections of the Code.
  • Revenue Procedure 2023-35 provides that the IRS will not treat a redemption of a share in any money market fund as part of a wash sale under Code 1091.
  • Proposed regulations that provide guidance on how manufacturers, producers and importers of designated drugs will report excise tax liability under § 5000D. The proposed regulations also would except such excise tax from semimonthly deposit requirements.

October 18, 2023: The IRS released Notice 2023-70, which provides the adjusted applicable dollar amount to be multiplied by the average number of covered lives for purposes of calculating the fee imposed by §§ 4375 and [...]

Continue Reading



read more

Weekly IRS Roundup October 9 – October 13, 2023

by | Oct 19, 2023 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 9, 2023 – October 13, 2023.

October 10, 2023: The IRS released Internal Revenue Bulletin 2023-41, which includes the following:

  • Revenue Ruling 2023-19 sets forth updated terminal charge and Standard Industry Fare Level formula mileage rates for valuing noncommercial flights on employer-provided aircrafts for purposes of taxing fringe benefits under Treasury Regulation § 1.61-21(g).
  • Notice 2023-68 provides the special per diem rates for purposes of substantiating ordinary and necessary business expenses relating to (1) meal and incidental expenses within the transportation industry, (2) incidental expenses only and (3) allowances under the high-low substantiation method.
  • Revenue Procedure 2023-32 publishes the amount of unused housing credit carryovers allocated to qualified states under Code Section 42(h)(3)(D) for calendar year 2023.
  • Announcement 2023-29 revokes tax-exempt status from certain organizations.

October 10, 2023: The IRS reminded taxpayers filing on extension to gather all records and copies of missing documents before they prepare their returns on their own or visit a tax preparer.

October 12, 2023: The IRS released new tax gap projections for tax years 2020 and 2021. The projections estimate an increase in the gross tax gap to $688 billion in tax year 2021, which reflects a rise of more than $192 billion from prior estimates for tax years 2014 through 2016 and a rise of $138 billion from the revised projections for tax years 2017 through 2019.

October 13, 2023: The IRS released Notice 2023-71, extending all tax filing and payment deadlines from October 7, 2023, until October 7, 2024, for taxpayers affected by the recent terrorist attacks in Israel. The relief applies to:

  • Any individual whose principal residence or business entity is located in Israel, the West Bank or Gaza
  • Any sole proprietor whose principal place of business is located in Israel, the West Bank or Gaza
  • Any individual, business, sole proprietor, estate or trust whose books, records or tax preparer is located in Israel, the West Bank or Gaza
  • Any individual who was killed, injured or taken hostage during the terrorist attacks
  • Any individual affiliated with a recognized government or philanthropic organization and is assisting in Israel, the West Bank or Gaza (such as a relief worker)

October 13, 2023: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).



read more

Weekly IRS Roundup October 2 – October 6, 2023

by | Oct 16, 2023 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 2, 2023 – October 6, 2023.

October 2, 2023: The IRS released Internal Revenue Bulletin 2023-40, which includes the following:

  • Revenue Ruling 2023-18 provides the October 2023 applicable federal rates.
  • Notice 2023-64 provides interim guidance on the new corporate alternative minimum tax (CAMT) and indicates that proposed regulations are forthcoming. The notice describes rules for:
    • Determining a taxpayer’s applicable financial statement and adjusted financial statement income (AFSI), including rules applicable to tax consolidated groups and certain foreign corporations
    • AFSI adjustments for the depreciation of Section 168 property, the amortization of qualified wireless spectrum, the treatment of certain taxes and to prevent certain duplications and omissions
    • Determining the applicable corporation status, the CAMT foreign tax credit and financial statement net operating losses.
  • Notice 2023-66 updates the corporate bond monthly yield curve, the corresponding spot segment rates for September 2023 used under § 417(e)(3)(D), the 24-month average segment rates for September 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
  • Revenue Procedure 2023-30 provides specifications for the private printing of red ink substitutes for the 2023 revisions of certain information returns.
  • Revenue Procedure 2023-31 refers filers to applicable publications, forms, instructions or other guidance, including postings on IRS.gov, for procedures related to seeking a hardship waiver or administrative exemption from requirements to file Forms 8955-SSA and 5500-EZ electronically.

October 3, 2023: A public meeting of the Electronic Tax Administration Advisory Committee will be held on November 15, 2023.

October 5, 2023: The IRS warned high-income taxpayers to avoid promotions involving inflated deductions for art donations. The IRS indicated that schemes involving abusive art donations are on its radar and that multiple investigations are underway.

October 6, 2023: The IRS released proposed regulations addressing so-called “Killer B” transactions. These transactions, at a high level, are structured to repatriate foreign subsidiary earnings through triangular reorganizations. The proposed regulations would formalize and modify guidance set forth in Notices 2014-32 and 2016-73.

October 6, 2023: The IRS issued proposed regulations, Revenue Procedure 2023-33 and frequently asked questions on the transfer of new and previously owned clean vehicle credits from a taxpayer to an eligible entity for vehicles placed in service after December 31, 2023. This guidance addresses how taxpayers can elect to transfer new and previously owned clean vehicle credits to dealers who are eligible to receive advance payments of either credit, how dealers can become eligible entities to receive advance payments of new or previously owned clean vehicle credits and how to recapture the credit.

October 6, 2023: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).



read more

BLOG EDITORS

Kevin Spencer

Evan Walters

STAY CONNECTED

Subscribe

TOPICS

ARCHIVES

jd supra readers choice top firm 2023 badge