Searching Content indexed under Tax Authorities 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 Bd, which involves a dispute as to whether an unpublished letter by a Department of Education official...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
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 The Tax Court issues two categories of opinions: (1) formally published dispositions; and (2) unpublished dispositions.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
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. ง 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
Inversions And Debt/Equity Regulations Top Treasury's 2016–2017 Priority Guidance Plan
The public is invited to continue to provide comments and suggestions as guidance is written throughout the year.
United States
17 Aug 2016
Tax Court Trial Sessions – How A Case Is Set For Trial
The Tax Court will issue a notice setting the case for trial approximately five months before the trial date.
United States
12 Aug 2016
Offshore Voluntary Disclosure Update
Each program has its own set of tailored procedures and eligibility requirements.
United States
12 Aug 2016
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
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