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Revenue Procedures Tax Liability

Jones Day

IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

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A new program offers rulings in 12 weeks, even absent a showing of business need. Revenue Procedure 2023-26, issued July 26, 2023, in replacement of a popular 18-month pilot program under Revenue Procedure 2022-10,...more

Morgan Lewis

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

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A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

Williams Mullen

[Webinar] December 2022 Tax Forum - December 1st, 9:00 am - 10:00 am ET

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Join Williams Mullen for our Winter Tax Forum on Thursday, December 1, 2022, where Farhad Aghdami will provide an update on recent wealth transfer tax developments and Kevin Bender will provide an update on a new IRS revenue...more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 23, 2022

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2022 – April 23, 2022... April 18, 2022: The IRS issued Revenue Ruling 2022-9,...more

Freeman Law

Court Declares IRS Micro-Captive Notice 2016-66 Unlawful: What Taxpayers Should Do Now

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Introduction.  On May 17, 2021, the United States Supreme Court handed the IRS a significant loss when it concluded that CIC Services, LLC (“CIC”) could continue its lawsuit against the IRS for violations of the...more

McDermott Will & Emery

Weekly IRS Roundup January 30 – February 5, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 30, 2022 – February 5, 2022... January 31, 2022: The IRS issued Revenue Procedure...more

Jones Day

New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions

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On January 14, 2022, the Internal Revenue Service ("IRS") released Revenue Procedure 2022-10, which establishes a "fast-track processing" pilot program for certain private letter ruling requests that are solely or primarily...more

Freeman Law

Tax Court Grants Innocent Spouse Relief

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In the recent case of Todisco v. Commissioner of Internal Revenue, the Tax Court granted innocent spouse relief to the taxpayer, finding that it would be inequitable to hold her liable for the taxes at issue.  As a result,...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

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Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

McDermott Will & Emery

Weekly IRS Roundup September 27 – October 1, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

Freeman Law

The Tax Court in Brief - February 2021 #4

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of February 22 – February 26, 2021 - Llanos v. Commissioner...more

Freeman Law

IRS Updated Revenue Procedure for Reducing or Avoiding Understatement Penalties and Tax Return Preparer Penalties

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Recently, the IRS issued Revenue Procedure 2020-54, which updated Revenue Procedure 2019-42. Specifically, this new Revenue Procedure identifies circumstances under which the taxpayer makes an adequate disclosure on a...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

McDermott Will & Emery

Weekly IRS Roundup October 5 – October 9, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 28, 2020 – October 2, 2020... October 7, 2020: The IRS published final regulations...more

Perkins Coie

Tax Relief and Estate Planning Strategies in the Wake of COVID-19

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IRS Grants Automatic Extension of Federal Tax Returns - Between March 17 and April 9, 2020, the U.S. Department of the Treasury and the Internal Revenue Service issued a series of notices automatically extending to July 15...more

Foster Garvey PC

The IRS and Treasury Are Working Overtime to Provide Taxpayers with Joy, Hope and Optimism During These Trying Times

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NOTICE 2020-23 - On April 9, 2020, the U.S. Secretary of the Treasury issued Notice 2020-23. It greatly expands the tax compliance relief previously granted to taxpayers in response to the COVID-19 pandemic....more

Burr & Forman

South Carolina Department of Revenue Issues Draft Guidance Announcing New Procedures For Handling Disputed State Tax Matters

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The South Carolina Department of Revenue (SCDOR or DOR) recently issued a draft of long-awaiting guidance overhauling DOR’s administrative practices concerning disputed tax audits, refunds, license revocations, and other...more

McDermott Will & Emery

Weekly IRS Roundup December 30, 2019 – January 3, 2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 30, 2019 – January 3, 2020. December 30, 2019: The IRS issued a news release announcing...more

McDermott Will & Emery

Weekly IRS Roundup December 9 – 13, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 9 – 13, 2019. December 10, 2019: The IRS issued a notice providing that the requirement...more

McDermott Will & Emery

Weekly IRS Roundup September 30 – October 4, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30 – October 4, 2019. September 30, 2019: The IRS published a draft of the tax year...more

McDermott Will & Emery

Weekly IRS Roundup September 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more

McDermott Will & Emery

Weekly IRS Roundup September 2 – 6, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 2 – 6, 2019. September 3, 2019: The IRS issued a notice in which it released the...more

McDermott Will & Emery

Weekly IRS Roundup April 29 – May 3, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29 – May 3, 2019. April 29, 2019: The IRS issued a news release urging taxpayers who had...more

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