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Tax Court to Consider Relevancy Threshold for Economic Substance Doctrine Under Section 7701(o)

The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions. In a July 19, 2024, order in...more

US Tax Court Voids Penalties Affecting Syndicated Conservation Easements; Treasury Reacts With Proposed Regulations

The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions. Key Points: ..Notice 2017-10...more

COVID-19: IRS Postpones Most Tax Deadlines; Court and Agency Closures Delay Federal Tax Cases – UPDATE

Updated guidance relieves most tax deadlines, provides new procedures for claiming tax relief, and addresses communications with the IRS during the widespread shutdown. ...more

COVID-19: IRS Postpones Tax Deadlines and Court and Agency Closures Will Delay Federal Tax Cases

Notice 2020-18, expanded by Notice 2020-20, provides welcome economic relief from filing and payment obligations for certain federal taxes; however, traps for the unwary exist. Tax Deadline – Key Points: ..On March 20,...more

COVID-19: IRS Announces Further Taxpayer Relief With “People First Initiative”

News release details operational changes and additional administrative relief for taxpayers facing uncertainty due to COVID-19. Key Points: ..The IRS is prioritizing taxpayer and IRS personnel safety and security with...more

COVID-19: IRS Postpones Tax Deadline and Court and Agency Closures Will Delay Federal Tax Cases

Notice 2020-18 provides welcome economic relief from filing and payment obligations for certain federal income taxes; however, traps for the unwary exist. Tax Deadline – Key Points: ..On March 20, 2020, the Internal Revenue...more

IRS Launches New Compliance Campaigns on Repatriation of Foreign Earnings and Virtual Currency

LB&I has announced compliance initiatives regarding the Section 965 Transition Tax, Repatriation via Foreign Triangular Reorganizations, and Virtual Currency transactions. Key Points: ..The IRS continues its efforts to...more

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