Searching Content indexed under Tax by Andrew Roberson ordered by Published Date Descending.
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IRS Rules (Again) That Taxpayers Are Not Entitled To Claimed Refined Coal Credits
This, according to the IRS, was fatal to any claim by the taxpayers to refined coal credits related to the LLC's production of refined coal.
United States
11 Aug 2017
Formal Document Requests – The IRS's Tool For Collecting "Foreign-Based Documentation"
One important feature of every audit is the request and collection of relevant taxpayer materials by the Internal Revenue Service (IRS).
United States
17 Nov 2016
IRS Litigation Guideline Memorandums Obsoleted
The Internal Revenue Service (IRS) issues many forms of public and private guidance, both to government personnel and to taxpayers.
United States
14 Nov 2016
IRS Issues Regulations Related To CFC Loans
The IRS has just released final regulations regarding the treatment of United States property held by a CFC in connection with certain transactions involving partnerships.
United States
10 Nov 2016
Supreme Court Grants Certiorari In Case Involving Auer Deference
The US Supreme Court (Supreme Court) granted certiorari in the case of Gloucester County Sch. Bd, which involves a dispute as to whether an unpublished letter by a Department of Education official...
United States
9 Nov 2016
The Interplay Between Tax Planning And IP Planning
On November 3, 2016, we presented at the Chicago Tax Club's symposium regarding tax planning and intellectual property (IP) planning within a multinational corporation.
United States
7 Nov 2016
APA Challenge To Notice Of Deficiency: QinetiQ Oral Arguments
On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192.
United States
4 Nov 2016
Former Tax Court Judge Pleads Guilty To Tax Crimes
Following up on our prior coverage, former US Tax Court Judge Diane L. Kroupa pleaded guilty on Friday to multiple tax criminal charges related to her tax returns and interactions with the Internal Revenue Service.
United States
25 Oct 2016
IRS Issues IPU On Identifying Foreign Goodwill Or Going Concern
On October 13, 2016, the IRS released an LB&I International Practice Unit, providing guidance to IRS agents relating to the identification of foreign goodwill or going concern value...
United States
20 Oct 2016
Types Of Tax Court Opinions And Their Precedential Effect
Most tax cases are decided by the US Tax Court (Tax Court). The Tax Court issues two categories of opinions: (1) formally published dispositions; and (2) unpublished dispositions.
United States
19 Oct 2016
UTP Filings Continue To Rise
The IRS has released statistics for the 2010 to 2014 tax years relating to Schedule UTP filings, showing that there were 6,320 uncertain tax positions reported in 2014.
United States
18 Oct 2016
Tax Controversy Options
Knowing your options for a US Federal tax controversy is helpful in creating a sound and efficient strategy.
United States
17 Oct 2016
Tax Court Anticipates Releasing Revisions To Its Rules In The Near Future
At the ABA Section of Taxation meeting in Boston last week, Chief Judge Marvel of the US Tax Court announced that the court anticipates issuing revisions to its rules in the near future.
United States
6 Oct 2016
IRS Updates Rules Regarding Appeals Conferences
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016:
United States
26 Sep 2016
Privileged Materials Provided Without Taxpayers' Consent Should Not Waive Privilege
In today's tax environment and with the potential monetary awards to whistleblowers under Internal Revenue Code (Code) Section 7623...
United States
20 Sep 2016
GAO Reports On IRS Guidance Procedures
The United States Government Accountability Office (GAO) recently released a report regarding how the Internal Revenue Service (IRS) communicates tax guidance to the public.
United States
13 Sep 2016
3M Company, IRS File Reply Briefs In "Blocked Income" Case; Tax Court Orders Oral Argument
3M returns to its argument that Treas. Reg. § 1.482-1(h)(2) is "procedurally invalid" because Treasury and the IRS failed to satisfy the requirements of section 553 of the APA when they promulgated the regulations.
United States
8 Sep 2016
IRS Begins Formal Assessment Of CAP Program
On August 26, the Internal Revenue Service (IRS) announced that its Large Business & International (LB&I) division is in the process of assessing the Compliance Assurance Process (CAP) program.
United States
1 Sep 2016
Taxpayer Argues First Circuit Should Not Follow Tax Court Decision By Judge Indicted For Tax Fraud
We will continue to follow these matters and provide updates in the future.
United States
24 Aug 2016
Sixth Circuit Defines ‘Corporation' For Purposes Of Overpayment Interest
The Sixth Circuit held that a nonprofit entity incorporated under state law falls within the definition of a ‘corporation' for purposes of determining the interest rate applicable to tax refunds.
United States
23 Aug 2016
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