News & Analysis as of

Internal Revenue Service Document Requests

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
McDermott Will & Emery

Ninth Circuit Interprets Summons Notice Rules Strictly Against IRS

The Internal Revenue Service (IRS) had broad examination authority to determine the correct amount of tax owed by taxpayers. In addition to seeking information directly from a taxpayer, the IRS is also authorized to seek...more

Jones Day

Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination

Jones Day on

This video is the first in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage one - planning for and handling the IRS examination. He emphasizes the importance of...more

Foodman CPAs & Advisors

If IRS wants to obtain records held in another country, Don’t ignore its request!

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982...more

Carlton Fields

Domestic Partnership Agreements: Financial Disclosures and Privacy

Carlton Fields on

To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each other prior to signing the agreement. Each partner should disclose to the...more

Blank Rome LLP

High Court Opens Door To IRS Personnel Examination

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The U.S. Supreme Court issued a unanimous opinion Thursday in United States v. Clarke (No. 13-301) addressing the standard that must be satisfied before a taxpayer can question Internal Revenue Service personnel about its...more

Skadden, Arps, Slate, Meagher & Flom LLP

"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

King & Spalding

New Mandatory Enforcement Process For Information Document Requests in Large Business and International Tax Examinations

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On January 2, 2014, the Large Business & International (“LB&I”) Division of the Internal Revenue Service began using a new mandatory enforcement process for delinquent information document requests (“IDRs”) in tax...more

McDermott Will & Emery

The Other Shoe Drops

McDermott Will & Emery on

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

BakerHostetler

IRS Announces New Mandatory IDR Procedures

BakerHostetler on

Tax Analysts Tax Notes reports that the IRS Large Business and International Division (LBI) released mandatory, stringent new procedures for enforcing information document requests (IDRs) and issuing summonses, minimizing...more

Skadden, Arps, Slate, Meagher & Flom LLP

"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

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