News & Analysis as of

Tax Assessment Internal Revenue Code (IRC)

Cadwalader, Wickersham & Taft LLP

IRS Private Letter Ruling Says CPACE Loans Qualify for REMIC Transactions

The IRS recently concluded that certain commercial property assessed clean energy (“CPACE”) assets are “obligations . . . secured by an interest in real property” under Code Section 860G(a)(3) in a private letter ruling...more

Holland & Knight LLP

IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

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The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

Paul Hastings LLP

The IRS Can Obtain Your Bank Records Without Your Knowledge

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The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more

Freeman Law

IRS Issues Proposed Regulations under Section 6751(b)

Freeman Law on

When is Written Managerial Approval Required? In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the “Act”).  Buried within...more

Bilzin Sumberg

Playing Battleship with the IRS: Assessing the Damages

Bilzin Sumberg on

In a prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s  recently issued decision in Alon Farhy v. Commissioner, 160 T.C. No. 6 (April...more

Freeman Law

Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of...

Freeman Law on

In the federal income tax world, there are effectively two functions within the Internal Revenue Service (“IRS”).  First, the IRS examines tax years and tax returns to determine whether the taxpayer has reported the correct...more

Freeman Law

No Right to Intervene?—IRS Third-Party Summonses

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Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more

McDermott Will & Emery

What are the Time Limits for Assessing Additional Federal Tax and Filing a Refund Claim?

The Internal Revenue Service (IRS) must follow the “statute of limitations” as stated in Internal Revenue Code (IRC) Section 6501 to “assess” additional federal tax. Likewise, taxpayers must seek a tax overpayment or refund...more

Freeman Law

How Long Can the IRS Levy on Social Security Benefits?

Freeman Law on

To levy on Social Security benefits, the IRS generally issues Form 668-W to the Social Security Administration (“SSA”). After receipt of the Form 668-W, Notice of Levy on Wages, Salary, and Other Income, SSA will withhold...more

Gray Reed

Statute of Limitations in Tax Cases – The Basics

Gray Reed on

What is the Statute of Limitations? - The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations.  The first is the period during which the IRS can assess...more

Gray Reed

The Basics of IRS Assessments

Gray Reed on

An assessment results when the liability of a taxpayer is recorded in the office of the Secretary of the Treasury.  The assessment establishes the right of the IRS to collect the tax. ...more

Morgan Lewis

Sovereign Wealth Funds Update: Tax Aspects of Private Fund Investments: Selected US, EU, and UK Considerations in the Current...

Morgan Lewis on

Despite the market disruption caused by the COVID-19 pandemic, sovereign wealth funds continued to make significant capital commitments to private funds during 2020, on a global basis. As the world emerges from the pandemic,...more

Burr & Forman

Section 4980H Employer Shared Responsibility Payments (ESRP): The New “IRS Employment Tax Penalty”?

Burr & Forman on

Many employers began to receive notices from the IRS in 2018 proposing the assessment of a payment against the employer for the tax years 2015 and 2016 under Section 4980H of the Internal Revenue Code. The issuance of these...more

Williams Mullen

Virginia Real Property Tax Prepayment Limitation Under the New Federal Income Tax Law

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Many individual taxpayers are rushing to prepay their real property taxes in anticipation of the new lower cap of $10,000.00. Not everyone will be able to take advantage of the tax planning idea. ...more

Bowditch & Dewey

Current Issues for Higher Education Real Estate Lawyers

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Campus Real Estate, Property Management, Tax Credits The 15th Annual Higher Education Real Estate Lawyers conference was held in San Francisco, where attendees listened to and learned from both in-house and outside counsel at...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Congress Overhauls Partnership Audit and Litigation Procedures"

On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more

Pullman & Comley, LLC

Property Valuation Topics: Winter 2015

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Thorny Exemption Issue Discussed - Limited Liability Company X owns property in the Town of Windham which it leases to Corporation Y. Both entities are tax exempt under the Internal Revenue Code. Both entities...more

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