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Morgan Lewis

Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

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Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

Venable LLP

ERTC Refund Lawsuits: Is Now the Time to File?

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Many employers who filed employee retention tax credit (ERTC) refund claims have been waiting months or even years to receive refund checks. The IRS stopped processing refund claims in mid‑July of 2023 and publicly announced...more

McDermott Will & Emery

IRS (Belatedly) Strikes Back Against FedEx in Ongoing Foreign Tax Credit Case

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FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...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

Jones Day

Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference

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In this installment of Jones Day's continuing series of videos focusing on tax disputes, partner and tax litigator Chuck Hodges explains the Appeals Judicial Approach and Culture ("AJAC") Project's rules and procedures and...more

Jones Day

Jones Day Presents: Overview of IRS Appeals Judicial Approach & Culture Project (AJAC)

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The appeals process remains a critical component in resolving tax disputes with the U.S. federal government. As such, the IRS introduced the Appeals Judicial Approach and Culture ("AJAC") Project to introduce a quasi-judicial...more

Jones Day

Jones Day Presents: Strategies for Dealing with the IRS: Going to Court

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This video is the final in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage four - going to court. He describes the three courts available to taxpayers when they...more

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