Kevin M. Johnson

Kevin M. Johnson

Pepper Hamilton LLP

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Latest Publications


IRS Restructuring LB&I Division and Audit Process Again - Tax Update Vol. 2015, Issue 4

The changes include a move toward more issue-focused and efficient audits, which should benefit both the IRS and its taxpayers. It seems like the Internal Revenue Service (IRS) reorganizes its Large Business and...more

12/9/2015 - Audits Corporate Taxes IRS

The Game Has Changed: Congress Enacts Changes to IRS Partnership Audit Rules That Could Force Partnerships to Pay Tax - Tax Update...

The Bipartisan Budget Act will allow the IRS to collect taxes associated with audit adjustments at the partnership level, rather than passing adjustments through to the individual partners, effectively imposing entity-level...more

12/9/2015 - Audits Bipartisan Budget IRS Partnerships Tax Planning

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your...more

8/27/2014 - BEPS Corporate Taxes Income Taxes Multinationals OECD Tax Liability

As Foreign Banks May Disclose U.S. Depositors, Foreign Account Holders Should Consider IRS OVDI Program

In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more

3/29/2013 - FBAR Foreign Banks IRS OVDP Tax Evasion UBS

The Demise of the IRS Tiered Issue Program

In news greatly welcomed by the tax community, IRS Large Business and International (LB&I) Commissioner Heather C. Maloy announced in a directive issued in late August that the IRS is ending its Tiered Issue Program....more

12/3/2012 - IRS

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