The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more
5/1/2025
/ Digital Assets ,
Disclosure Requirements ,
Executive Orders ,
Filing Requirements ,
Government Agencies ,
IRS ,
New Guidance ,
Regulatory Reform ,
Reporting Requirements ,
Rulemaking Process ,
Small Business ,
Taxation
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025.
IRS GUIDANCE -
March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more
Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025.
Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition...more
3/17/2025
/ Employee Benefits ,
Income Taxes ,
Interest Rates ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Regulatory Requirements ,
Tax Credits ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Tax Returns ,
U.S. Treasury
On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
3/13/2025
/ Appeals ,
Chevron Deference ,
Corporate Taxes ,
FedEx ,
Foreign Tax Credits ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Offsets ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Tax Avoidance ,
Tax Credits ,
Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025.
TAX-CONTROVERSY-RELATED DEVELOPMENTS -
The previous IRS...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025.
TAX CONTROVERSY-RELATED DEVELOPMENTS -
January 15, 2025: The US...more
2/5/2025
/ Appeals ,
Clean Energy ,
Corporate Taxes ,
Dispute Resolution ,
Final Rules ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Renewable Energy ,
Revenue Procedures ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Tax Returns
On January 22, 2025, the US Department of Justice (DOJ) announced the indictment of seven individuals in the largest Employee Retention Credit (ERC) fraud scheme to date. According to the indictment, the defendants filed more...more
1/29/2025
/ Coronavirus/COVID-19 ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Employee Retention ,
Employer Liability Issues ,
Enforcement Actions ,
Fraud ,
Indictments ,
IRS ,
Paid Family Leave Law ,
Paid Leave ,
Sick Leave ,
Tax Credits ,
Tax Refunds ,
Tax Returns
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025....more
1/23/2025
/ Digital Assets ,
Income Taxes ,
IRS ,
Proposed Rules ,
Regulatory Agenda ,
Reporting Requirements ,
Retirement Plan ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
Tax Refunds ,
Tax Returns
A US federal district court judge recently endorsed the broad investigative powers of the Internal Revenue Service (IRS) in United States v. Eaton Corp., No. 1:23-mc-00037, May 16, 2024 (N.D. Ohio). During its audit of...more
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more
FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more
In United States v. Grigsby, Docket No. 22-30764, the US Court of Appeals for the Fifth Circuit held that a refund claim based on claimed Internal Revenue Code (IRC) Section 41 credits was erroneous. Cajun Industries LLC, a...more
On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more
10/24/2023
/ Corporate Counsel ,
Corporate Taxes ,
Foreign Corporations ,
High Net-Worth ,
Income Taxes ,
Individual Retirement Account (IRA) ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Audits ,
Tax Incentives
Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large...more
In this article, we discuss some basic considerations for preparing a protective refund claim. These considerations are particularly relevant for taxpayers whose statutes of limitations for refund claims are expiring soon and...more
On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more
On July 6, 2023, the US Tax Court issued its decision in Betz v. Commissioner, T.C. Memo. 2023-84. Betz considers the application of the pilot model supply rule to expenses incurred by a designer (CPI) of made-to-order air...more
Two recent decisions confirmed the broad administrative summons authority of the Internal Revenue Service (IRS). In the first, the US Supreme Court resolved a circuit conflict regarding notice requirements for third-party IRS...more