Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Estate of DeMuth, v. Comm’r, T.C. Memo. 2022-72 | July 12, 2022 | Jones, J. | Dkt. No. 18724-19 Whistleblower 972-17W v. Comm’r, 159 T.C. No. 1 | July 13,...more
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
On May 12, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-104591-18) that address the disallowance of deductions for amounts paid or incurred for...more
The Internal Revenue Service has issued Notice 2018-23 (dated March 27, 2018) to implement transitional guidance for application of new IRC secs. 162(f) and 6050X. As described in our previous Client Advisory, those new tax...more
A minor provision concerning deductibility in Public Law 115-97, commonly known as the Tax Cuts and Jobs Act (Act), may have significant impacts on administrative and judicial settlements between companies and the U.S....more
The new tax law changed the deductibility of settlements with government agencies in some circumstances thereby increasing the cost to companies to settle these cases. The deduction arose from the section in the Internal...more
Fines pertaining to violations of federal securities laws and certain FINRA rules may not be deducted. The Internal Revenue Service (IRS) in low-level advice recently announced its position that certain fines paid to...more