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McDermott Will & Emery

The Employee Retention Credit: IRS’s “Risking” Model Faces Legal Challenge

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Case: ERC Today LLC et al. v. John McInelly et al., No. 2:24-cv-03178 (D. Ariz.) In an April 2025 order, the US District Court for the District of Arizona denied a motion for a preliminary injunction filed by two tax...more

McDermott Will & Emery

Weekly IRS Roundup December 26 – December 30, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022...more

Freeman Law

Willful FBAR Penalties and a District Court’s Authority to Remand IRS Willful Penalty Computations

Freeman Law on

Willful FBAR Penalties - The Schwarzbaum case has received a lot of attention in the last few years from tax professionals.  For example, in 2020, the district court concluded—contrary to some other federal court...more

Freeman Law

The Art of an IRS APA Defense: Conservation Easements and Hewitt

Freeman Law on

Good tax attorneys will do whatever it ethically takes to win on behalf of their clients.  Often, this means the attorney must not only have a good understanding of the substantive provisions at play, but also relevant...more

Sullivan & Worcester

A Warm Welcome to the Tax Trotter

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Happy New Year and welcome to the Tax Trotter! What a year 2020 has been! Stock markets running high, travel low, Zoom reigning supreme with the blue light eyeglass filter becoming as popular as the anti-glare...more

Skadden, Arps, Slate, Meagher & Flom LLP

Challenging Tax Cuts and Jobs Act Regulations and IRS Guidance

The Tax Cuts and Jobs Act (TCJA) brought sweeping changes to the U.S. international tax system. Along with those changes came substantial taxpayer uncertainty as to how the TCJA’s rules apply to their unique circumstances....more

Nossaman LLP

IRS Data Breach Class Action Dismissed

Nossaman LLP on

Last week, the Internal Revenue Service successfully defeated a putative class action related to a data breach it suffered in 2015. The D.C. District Court’s decision dismissing the suit demonstrates the high bar required to...more

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