Future Tax Treatment

IRS ‘Repairs’ The Examination Of Tangible Property Regulation Issues

In March, the Internal Revenue Service published an IRS Large Business & International (LB&I) Directive (the Directive), which updates an earlier directive to field agents addressing the examination of capitalization and...more

Representations Of Future Tax Treatment To Induce Creation Of Pension Plan Are Not Actionable As A Matter Of Law

The California Fourth District Court of Appeal adopted the principle that it is inherently unreasonable for any person to rely on a prediction of future IRS enactment, enforcement, or non-enforcement of the law by someone...more