Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
IRS Inquiries and Examinations, Generally – Sections 6201 and 7602. Generally, the IRS is authorized and required by 26 U.S.C. § 6201(a) “to make the inquiries, determinations, and assessments of all taxes” imposed by the...more
En el comentario “A Closer Look: Impacting the Tax Gap”, el Comisionado del IRS, Chuck Rettig, revela que el IRS ha cambiado su enfoque de fiscalización a declaraciones de impuestos que incluyen contribuyentes de altos...more
In the third in a series of Jones Day’s video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains the Acknowledgment of Facts IDR, and...more
Recently, the IRS issued Notice 2017-12, providing further guidance on ways to confirm that the IRS has closed its examination of an estate tax return. Notice 2017-12 officially confirms what the IRS website has said for...more
Recently announced changes to the Internal Revenue Service (IRS) Large Business and International (LB&I) Division’s examination process include a requirement that the audit team issue an Information Document Request (IDR)...more
On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces...more