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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 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

Planning for Tax Controversies Before, During and After the Deal: New Dynamics in Cross-Border M&A Under the TCJA

Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more

Cross-Border Financing: Taxpayer Wins on Characterization of Intercompany Debt Transaction

Certainty regarding characterization of intercompany transactions remains a priority after US tax reform, opinion highlights importance of established pattern of conduct. On August 6, 2018, the US Tax Court decided...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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