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
This is the fourth edition of the Eversheds Sutherland SALT Scoreboard for 2023. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
VVF Interest LLC (“VVF”), represented by Buckingham attorneys Rich Fry, Steve Dimengo and Nate Fulmer, notched a significant victory at the Ohio Board of Tax Appeals for the situsing of its sales for Ohio commercial activity...more
The California Office of Tax Appeals (OTA) recently held that a California resident’s income tax paid to Massachusetts from the sale of his membership interest in a limited liability company (LLC) doing business in...more
In a long-awaited decision, the Pennsylvania Supreme Court recently held in Synthes USA HQ, Inc. v. Commonwealth, 11 MAP 2021, that service providers were required to apportion receipts based on the location where the...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
Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more
The U.S. District Court for the District of Delaware held that corporate income tax liability attributable to transactions before the filing of a bankruptcy petition are nevertheless administrative expenses because the...more
The California Office of Tax Appeals will hold an informal interested parties meeting on April 3, 2020, to discuss proposed amendments to its rules for tax appeals....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11–15, 2019. November 11, 2019: The IRS released Delegation Order 30-9 announcing the...more
Recently, the Ohio Board of Tax Appeals (BTA) denied a taxpayer’s sales tax refund in part because it could not consider the taxpayer’s improperly submitted evidence. In Environmental Quality Management Inc. v. McClain, BTA...more
In the fifth installment of Jones Day's series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS's new fast track...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
The enactment of the Taxpayer First Act, H.R. 3151 (116th Cong.) (TFA) brings with it several changes to the procedures and operations of the Internal Revenue Service (IRS). The TFA touches on the following subjects... ...more
This video is the second in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage two – the IRS Office of Appeals. He describes the office as having one mission – to...more