K. Christy Vouri

K. Christy Vouri

McDermott Will & Emery

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IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

2/3/2015 - FBAR Foreign Financial Accounts IRS Offshore Funds OVDP Voluntary Disclosure

IRS Lacks Authority to Issue and Enforce Tax Return Preparer Regulations

On February 11, 2014, the U.S. Court of Appeals for the District of Columbia upheld the decision of the District Court for the District of Columbia, affirming that the Internal Revenue Service (IRS) lacked the authority to...more

2/21/2014 - IRS Tax Preparers Tax Returns

Safe Harbors for Rehabilitation Tax Credits

On December 30, 2013, the Internal Revenue Service issued much anticipated guidance, in the form of Revenue Procedure 2014-12, providing a safe harbor under which it will not challenge a partnership’s allocations of...more

1/16/2014 - IRS Rehabilitation Benefits Safe Harbors Tax Credits

The Supreme Court Downplays the Blue Book’s Interpretative Value

On December 3, 2013, the Supreme Court of the United States dismissed the applicability of the Blue Book, a commentary of recently passed tax laws prepared by the Joint Committee on Taxation, as little more than a law review...more

12/12/2013 - Joint Committee on Taxation Jurisdiction Legislative History Penalties SCOTUS Statutory Interpretation

Focus on Tax Controversy - December 2013

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more

12/5/2013 - Administrative Procedure Act False Claims Act Fraud IRS Mayo Foundation for Medical Ed Mayo Foundation v US Protective Claims SCOTUS Standard of Review State Taxes Tax Refunds Transfer Pricing Treble Damages U.S. Treasury US v Home Concrete & Supply Whistleblowers

The Other Shoe Drops

On November 4, 2013, the Internal Revenue Service (IRS) Large Business and International Division released a much anticipated directive on its new Information Document Request enforcement process. Scheduled to take effect in...more

11/19/2013 - Document Requests Enforcement IRS

U.S. Tax Court: 90 Days Is 90 Days, Shutdown or Not

On October 1, 2013, the majority of the U.S. government shut down, including the U.S. Tax Court. Despite the shutdown, the statutory deadline for filing a petition in the Tax Court cannot be extended. Under these...more

10/10/2013 - Filing Deadlines Government Shutdown Mailbox Rule Tax Returns

Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims

On September 9, 2013, the U.S. Court of Appeals for the Second Circuit held that the District Court had jurisdiction to hear the taxpayer’s case based on the taxpayer’s use of a protective refund claim....more

9/19/2013 - Refunds Tax Refunds Tax Returns

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