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Searching Content indexed under Income Tax by Andrew Roberson ordered by Published Date Descending.
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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
2
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
3
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
4
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
5
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
6
Protecting Confidential Taxpayer Information In Tax Court
Taxpayers value confidentiality, particularly if there is a dispute with the IRS that involves highly-sensitive trade secrets or other confidential information.
United States
25 Jul 2016
7
IRS Changes Streamlined Filing Compliance Procedures For Non-Willfulness Certification Forms
The Internal Revenue Service (IRS) recently modified the non-willfulness certification form that individual taxpayers must submit to enroll in the streamlined filing compliance procedures (SFCP).
United States
6 Apr 2016
8
Altera: How To Challenge Tax Regulations On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under section 482 requiring participants in qualified cost-sharing agreements (CSAs) to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
5 Oct 2015
9
Federal Circuit Narrowly Interprets Limitations Period For Foreign Tax Credit Refund Claims
The Federal Circuit is the first appellate court to address this issue, and taxpayers paying foreign taxes need to be aware of the ramifications of the decision.
United States
15 Sep 2015
10
Statute Of Limitation: Congress Overrules Home Concrete And Retroactively Removes Some Taxpayer Defenses
On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law.
United States
20 Aug 2015
11
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
12
IRS Clarifies Requirements For Establishing Non-Willful Conduct In Offshore Disclosure Cases
Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets.
United States
3 Feb 2015
13
Ensuring Timely Filing With Private Delivery Services
Most of us are aware of the timely-mailed-timely-filed "mailbox rule" contained within the Internal Revenue Code.
United States
4 Jun 2014
14
Tax Court Extends Implied Waiver Of Privilege To Taxpayers’ State of Mind Penalty Defense
The U.S. Tax Court concludes in AD Investment 2000 Fund LLC v. Commissioner that a taxpayer’s assertion of a state of mind penalty defense waives the attorney-client privilege with respect to tax opinions provided to the taxpayer in advance of filing the taxpayer return, even if the taxpayer explicitly disclaims reliance on the tax opinions.
United States
28 Apr 2014
15
IRS Revises Directive on IDR Issuance and Enforcement Process
On February 28, 2014, the Internal Revenue Service Large Business and International Division released updated guidance for examiners incorporating and superseding two directives relating to Information Document Requests.
United States
5 Mar 2014
16
Courts Continue Literal Interpretation Of Subpart F Rules On Income Inclusion
Consistent with prior judicial precedent, the U.S. Court of Appeals for the Fifth Circuit recently applied a literal interpretation of the Subpart F inclusion rules based on the plain meaning of Sections 951 and 956.
United States
19 Jul 2013
17
IRS Continues Pursuit Of Foreign Reporting Violations
In recent years, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) have increased their pursuit of individuals who failed to disclose foreign bank accounts and to file required tax and information returns.
United States
21 Jan 2013
18
Tax Court Makes Significant Amendments To Privilege And Discovery Rules
Taxpayers under audit should be aware of significant amendments to the U.S. Tax Court's rules on work product protection and the discoverability of draft expert witness reports and certain communications between counsel and experts.
United States
15 Aug 2012
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