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Audits Statute of Limitations

Allen Barron, Inc.

How to Prepare for an IRS Audit

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We are often asked how to prepare for an IRS audit. The first and most important thing to know is that speaking directly with the IRS is not in your best interest. IRS Revenue Officers (auditors) are skilled interrogators....more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

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Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

Allen Barron, Inc.

The Statute of Limitations for an IRS Audit

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What is the statute of limitations for an IRS audit? What rules extend the window for an IRS audit? How long does the IRS usually have to complete an audit of your taxes? Everyone may have a little fear in the back of...more

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

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What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Proskauer - California Employment Law

PAGA 2.0 – What Employers Need to Know As PAGA Reform Becomes Law

On June 27, 2024, by near-unanimous vote, the California Legislature passed two bills enacting much-needed reform to the Private Attorneys General Act (PAGA). We previously reported on the legislative compromise last week,...more

McAfee & Taft

Gavel to Gavel: Limits on copyright infringement not limited

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Earlier this month, the U.S. Supreme Court resolved a split between the circuit courts over whether the Copyright Act’s three-year statute of limitations limits the amount of damages a plaintiff may recover to a three-year...more

Mitratech Holdings, Inc

4 Legal Hold Tips We’re Grateful for This November

Mitratech Holdings, Inc on

Dive into the do’s and don’ts of data preservation, custodianship, legal hold release expectations, and more. It is the season of giving thanks, and we’d be remiss if we didn’t acknowledge the tips and tricks that...more

King & Spalding

CMS Publishes Final Rule Regarding CMPs for Late Reporting by Medicare Secondary Payers

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On October 11, 2023, CMS published a final rule (the Final Rule) regarding how and when CMS will impose civil monetary penalties (CMPs) for Medicare secondary payers (MSPs) that untimely report required information. The Final...more

McDermott Will & Emery

Meaningful Statute of Limitations for Unclaimed Property Audits and Enforcement Actions? Michigan Court of Appeals Says Yes!

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On January 19, 2023, the Michigan Court of Appeals affirmed two 2022 trial court orders, holding that initiating an unclaimed property audit does not toll (or freeze) the running of the statute of limitations (time-bar) for...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: October 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

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We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

Blank Rome LLP

Michigan Court of Appeals Holds That a Reduction in a Credit Is Not a “Deficiency”

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The Michigan Court of Appeals held that the statute of limitations does not prevent the Department of Treasury (“Treasury”) from reducing a credit in an otherwise closed year, despite acknowledging flaws in how the audit was...more

Eversheds Sutherland (US) LLP

Quashed: Delaware Supreme Court affirms decision quashing subpoena in AT&T unclaimed property audit

On June 1, 2021, the Delaware Supreme Court affirmed the Court of Chancery’s decision to quash an administrative subpoena seeking extensive records in an unclaimed property audit of AT&T. The Delaware Department of Finance...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

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Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Eversheds Sutherland (US) LLP

Top five unclaimed property trends for 2020

Unclaimed property audits and compliance issues will continue to be a challenge for companies in a wide range of industries. States view escheat as an important source of revenue, and contingent fee auditors will do their...more

Nossaman LLP

SCOTUS Stretches the Statute of Limitations Period for False Claims

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The U.S. Supreme Court is now in its summer recess and we anecdotally have heard of Justice “sightings” in Europe and beyond.  This last session of the Court addressed many issues capturing both the political and popular...more

Eversheds Sutherland (US) LLP

Delaware Dilemma: VDA or Unclaimed Property Audit

Delaware is instituting an aggressive push forward on its controversial unclaimed property audit program, as indicated in two recent announcements. The Secretary of State has announced that his office will begin sending...more

Bradley Arant Boult Cummings LLP

OIG Expands Exclusionary Authority

The Department of Health and Human Services, Office of Inspector General (OIG) published a final rule on January 12, 2017, expanding the OIG’s authority to exclude providers from participation in federal healthcare programs....more

Cadwalader, Wickersham & Taft LLP

2016 Year In Review: Securities Litigation And Regulation

2016 was an active year in securities litigation. In the first half of 2016 alone, plaintiffs filed 119 new federal class action securities cases. It was also a busy year for SEC enforcement proceedings, with a record 868...more

Eversheds Sutherland (US) LLP

Ten Things You Should Know About the 2016 Uniform Unclaimed Property Act

The 2016 Uniform Unclaimed Property Act (2016 Act) was adopted unanimously by the Uniform Law Commission (ULC) in a 49-0 vote at its 2016 summer meeting. The adoption of the revised model law is a significant step forward for...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 6

New York City Tribunal Rejects City’s Attempt To Forcibly Combine Bank And Its Mortgage Subsidiary - The New York City Tax Appeals Tribunal, affirming a determination of the Chief Administrative Law Judge, has held that...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Lowndes

New Partnership Audit Rules Heading Our Way?

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The budget bill introduced yesterday includes a proposal to revamp/streamline how partnerships are audited. Specifically, it would repeal the much maligned TEFRA (1982 Tax Equity and Fiscal Responsibility Act) rules....more

Franczek P.C.

Employee Benefits Alert - August 2015

Franczek P.C. on

Retirement Plans - IRS Issues Guidance on Benefit Suspension Voting under MPRA - As we have written in prior alerts, the Multiemployer Pension Reform Act of 2014 (MPRA) permits trustees of financially troubled...more

Bradley Arant Boult Cummings LLP

Tips and Traps Regarding the Statute of Limitations and Signing Statute Waivers

As you end your telephone conversation with the revenue examiner, you think to yourself, “Thank goodness, this one is finally over!” The audit of your biggest client started over three years ago, and has seemingly dragged on...more

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