The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC) (“Burlington”) the Upper Tribunal (“UT”) dismissed HMRC’s appeal, holding that the First-tier Tribunal (“FTT”) was right to conclude that the anti-abuse provision...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
The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more
In an unpublished opinion released on May 12 in Grayson Dailey v. SC Home Holdings, LLC (Op. No. 2024-UP-164), the South Carolina Court of Appeals upheld the tax sale of real property in Lexington County over the objection of...more
Tax legislation, and the decisions of tax courts and tribunals, can sometimes appear to be full of surprises. The decision of the UK’s Court of Appeal in Hargreaves Property Holdings Limited [2024] EWCA Civ 365,...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
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...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
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
A recent pair of decisions by the California Office of Tax Appeals examined the tax treatment of special dividends paid in connection with the acquisition of a corporate target. Private company acquisitions are...more
It wouldn’t be far-fetched to say that, as a species, we humans have a propensity – rooted in our instinctive tendency for self-preservation – toward denying anything we believe may cause us harm. It should come as no...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
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
When Boechler v. Commissioner was argued, I wrote about how the statute in the case presented several grammar and usage quandaries. Now, the Supreme Court has unanimously agreed: The statute's text is a mess....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
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
On May 28, 2020, New Jersey Governor Phil Murphy signed legislation that fixes July 1, 2020 as the deadline for filing 2020 real property tax appeals. The stated reason for adopting the law was to account for the inability to...more
A common LLC problem: LLC members are ready to call it quits on the LLC and divide their interests in the LLC’s real property. Some members may want to sell, receive cash, and recognize gains for tax purposes. Other...more
In an Order entered by the New Jersey Supreme Court on March 19, 2020, the filing deadlines for 2020 tax appeals for both County Boards of Taxation and the Tax Court of New Jersey were extended to the later of May 1, 2020 or...more
At 9:00 PM March 18, 2020, the US Tax Court (Tax Court) issued a press release announcing that it was closing its building. As we previously discussed, the Tax Court previously closed the building to the public but still...more
Assessor had spent little time with limited discovery prosecuting case - Name: Marion County Assessor v. Stutz Business Center, LLC - Date Issued: August 30, 2019 - Property Type: Vacant land - Assessment Years:...more
Tidbit on NNN lease property valuation - A sort of a humdrum ruling on the assessment appeal of a garden variety industrial building nevertheless offers a valuable insight as to proper use of the income valuation...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
As part of its continuing guidance to taxpayers and practitioners about how its resumption of activities following the government shutdown is impacting pending matters, the Internal Revenue Service has published Frequently...more