The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit parental support. Consistent with prior...more
The Organization for Economic Cooperation and Development recently proposed that consumer-facing businesses that make nonroutine profits would be taxed in market jurisdictions where consumers are located, regardless of where...more
With Congress now on August recess, it is a good time to highlight an important piece of tax legislation already enacted during the 116th United States Congress. On July 1, the Taxpayer First Act (the Act)—which attempts to...more
In light of a recent pilot program encouraging the inclusion of Exam members in Appeals conferences, as well as an indication that Appeals conferences will return to being face-to-face meetings, taxpayers may want to consider...more