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"Supreme Court Clarifies Standard to Challenge IRS Summons"

On June 19, 2014, the U.S. Supreme Court in United States v. Clarke1 held that a taxpayer has a right to conduct an examination of IRS officials regarding their reasons for issuing an administrative summons when the taxpayer...more

6/20/2014 - Bad Faith Document Requests IRS Request For Information SCOTUS Summons US v Clarke

Proposals May Signal Direction of Future Tax Reform

After several years of hearings and forums intended to develop broad-based support for comprehensive tax reform, on February 26, 2014, House Ways and Means Committee Chairman David Camp (R-Mich.) released a draft tax reform...more

4/22/2014 - Accounting Alternative Minimum Tax Corporate Taxes Debt Restructuring Derivatives Financial Products Foreign Tax Internal Revenue Code Partnerships Subpart F Tax Credits Tax Reform Ways and Means Committee

"Supreme Court Rules on Partnership Tax Shelter Penalties"

In United States v. Woods,1 the U.S. Supreme Court ruled unanimously for the government on two long-brewing disagreements over penalty jurisdiction in the partnership context and over the breadth of valuation misstatement...more

1/7/2014 - Income Taxes IRS SCOTUS TEFRA United States v Woods

"IRS Announces New IDR Enforcement Process"

On November 4, 2013, the Internal Revenue Service released an internal directive that completes a two-part process of reshaping the dynamic between taxpayers and IRS examiners during the information-gathering phase of an...more

11/7/2013 - Corporate Counsel Corporate Taxes Document Requests Enforcement IRS

White House Budget Proposes Numerous Tax Changes as Congressional Tax-Writing Committees Focus on Reform

On April 10, 2013, the White House released its proposed budget for fiscal year 2014. The budget contains significant tax proposals related to renewable energy, research and job creation, as well as numerous changes affecting...more

5/3/2013 - Barack Obama Federal Budget International Tax Issues Tax Incentives Tax Planning Tax Reform

"IRS Guidance on the Commencement of Construction Requirements for Tax Credits for Qualified Energy Facilities"

On April 15, 2013, the Internal Revenue Service released Notice 2013-29 (Notice), which established guidelines and a safe harbor to determine when construction has begun on a “qualified facility” for purposes of the renewable...more

4/17/2013 - Energy Energy-Efficiency Tax Credits Investment Tax Credits IRS Production Tax Credit Qualified Energy Facilities Tax Credits

"House Ways and Means Proposal Would Change the Tax Treatment of Partnerships and S Corporations"

The first congressional proposals to revamp partnership and S corporation taxation in connection with anticipated tax reform have surfaced. Framed as two alternatives, both options suggest significant, and, in the case of one...more

3/29/2013

"Temporary ‘Fiscal Cliff’ Solution Yields Important Tax Changes"

On January 2, 2013, President Obama signed the American Taxpayer Relief Act of 2012 (the TRA of 2012), which permanently extends certain federal income tax rate reductions first enacted in 2001 that were scheduled to expire...more

1/3/2013 - Alternative Minimum Tax American Taxpayer Relief Act Bush-Era Tax Cuts Capital Gains Dividends Electricity Estate Tax Fiscal Cliff Generation-Skipping Transfer Gift-Tax Exemption Income Taxes Renewable Energy Tax Credits Wind Power

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