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
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
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
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