Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
The IRS Independent Office of Appeals has renewed its focus on alternative dispute resolution (ADR). In this article, V&E counsel Stephen Josey examines the ADR program and dives into how the agency can tweak its mediation...more
On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more
In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more
When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on...more
The Internal Revenue Service (IRS) has invited suggestions on improving conference options at the Independent Office of Appeals (IRS Appeals) for taxpayers and representatives who are not located near an IRS Appeals office...more
Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more
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....more
The American Institute of CPAs (AICPA) has applauded the Internal Revenue Service for granting automatic penalty relief related to select 2019 and 2020 returns, but asked for two tweaks to the process: The group wants...more
Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more
State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 6, 2021 – December 10, 2021... December 6, 2021: The IRS published updated guidance on...more
We recently covered the Appeals Team Case Leader Conferencing Initiative: Summary of Findings and Next Steps (Appeals Summary) in relation to the participation of Large Business & International (LB&I) exam teams and Internal...more
When we previously wrote about the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS), we explained that the IRS generally must submit proposed refunds in...more
When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS. Normally a taxpayer will find an office examination has begun when he or she has...more
There is a general misconception about what the IRS can and cannot do. Owing money to the IRS is not like owing any other creditor. The IRS is one of only a few creditors who can seize and sell your home even though state...more
Overview of the Appeals Process - The goal of the Appeals Office is to settle as many cases as possible within the broad guidelines of its Mission Statement...more
If you haven’t read Part 1 of this blogpost, you might appreciate the background in that post. That post dealt primarily with the concepts of communication during the audit....more
More than three years ago, the Internal Revenue Service (IRS) revised the Internal Revenue Manual to provide IRS Appeals Division (Appeals) with discretion to invite representatives from the IRS Examination Division (Exam)...more
As the COVID-19 pandemic continues to impact our lives, federal and state taxing authorities understand the challenges individuals and businesses are facing, and have issued guidance and a variety of updates....more
Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more