News & Analysis as of

Subject Matter Jurisdiction Internal Revenue Code (IRC)

Paul Hastings LLP

The IRS Can Obtain Your Bank Records Without Your Knowledge

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The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more

Freeman Law

No Right to Intervene?—IRS Third-Party Summonses

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Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more

Gray Reed

Recent Supreme Court Case Provides Possible Pre-Assessment Judicial Review for Onerous Penalties

Gray Reed on

The Supreme Court’s recent decision in CIC Services, LLC v. Internal Revenue Service may have significantly expanded taxpayers’ ability to obtain immediate injunctive relief against onerous tax reporting requirement....more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

Freeman Law on

In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Freeman Law

[Webinar] Freeman Law’s Tax Court Examination Course: An Introduction to the Tax Court: Jurisdiction, Procedure, and Overview -...

Freeman Law on

This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more

Freeman Law

Recent Bankruptcy Court Ruling Addresses the Jurisdiction of Bankruptcy Courts to Hear Innocent Spouse Relief Cases

Freeman Law on

The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more

Latham & Watkins LLP

US Supreme Court Allows Challenge to IRS Rule to Go Forward Despite Anti-Injunction Act

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The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations. Key Points: ..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more

Holland & Knight LLP

U.S. Supreme Court Decision May Pave Way for Future IRS Lawsuits

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The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more

McDermott Will & Emery

Supreme Court Opens Door to APA Challenge of Overreaching IRS Information Reporting Regime

In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more

Eversheds Sutherland (US) LLP

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC - The Anti-Injunction Act has its limits

On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more

Alston & Bird

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

Alston & Bird on

Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more

Dorsey & Whitney LLP

The Supreme Court - June 27, 2017

Dorsey & Whitney LLP on

Cyan, Inc. v. Beaver Cty. Employees, No. 15-1439: Whether state courts lack subject matter jurisdiction over covered class actions that allege only Securities Act of 1933 claims....more

Jackson Walker

Davidson v. Henkel — What’s Going On With Nonqualified Deferred Compensation Plans and FICA

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In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more

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