News & Analysis as of

Tax Audits Dispute Resolution

Skadden, Arps, Slate, Meagher & Flom LLP

A Depleted IRS May Turn to Expedited Processes to Work Off Dispute Backlog

By any measure, 2025 was a tumultuous year for the Internal Revenue Service (IRS), leaving a slimmed-down organization struggling to implement new priorities and a workforce trying to catch its breath in the face of dizzying...more

Opportune LLP

IRS Tax Controversy Guide: Navigating the Process from Notice to Resolution

Opportune LLP on

Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax laws. These...more

Vorys, Sater, Seymour and Pease LLP

Ohio Legislature Proposes Changes to the Taxpayer Bill of Rights

The General Assembly has recently proposed legislation to update Ohio’s Taxpayer Bill of Rights. House Bill 613 (H.B. 613) has been introduced but not yet assigned to a committee for review. The Bill offers several sweeping...more

DLA Piper

Lifecycle of a transaction: tax disputes on intra-group debt

DLA Piper on

Where there is potential for a tax dispute, it is crucial to map your position early: proactively building a “defence” file can best prepare taxpayers for HMRC enquiries when they arise years later. Originally Published in...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Procedural Reforms Aim To Allow Early Resolution of Controversies With Businesses

Over the past few months, interest and attention in the world of U.S. tax has been focused on the OBBBA — the One Big Beautiful Bill Act. However, significant administrative and procedural changes have also occurred at the...more

Snell & Wilmer

IRS Issues Interim Guidance Eliminating the Acknowledgement of Facts and Expanding Access To Dispute Resolution Programs

Snell & Wilmer on

The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of July 28, 2025

Tax developments - IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs - Significant updates from the IRS Large Business & International (LB&I) Division will take...more

Burr & Forman

IRS Appeals Announces a Return to In-Person Settlement Cases

Burr & Forman on

The IRS and taxpayers often disagree in tax audits and other tax-related matters. The IRS Office of Appeals was established as a separate and independent office within the IRS, whose mission is to resolve these tax disputes,...more

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