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Tax Audits Penalties Tax Legislation

Mayer Brown

Supplementary Law No. 225/2026: Taxpayers' Defense Code

Mayer Brown on

On January 9, 2026, the final text of the Supplementary Law ("LC") No. 225/2026 was published in the Official Gazette of the Federal Government, which launches the Taxpayers´ Defense Code (the “Code”), establishing...more

White & Case LLP

Courts and Congress Say IRS Must Approve Civil Tax Penalties in Writing Before They Are Asserted

White & Case LLP on

For the last decade, the IRS has proactively asserted discretionary civil tax penalties that can be as high as 40 percent of the proposed tax liability. Oftentimes, the IRS has used penalties as bargaining chips to get...more

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