Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more
6/3/2024
/ Audits ,
Bipartisan Budget Act ,
Corporate Taxes ,
Default ,
IRS ,
Jurisdiction ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Returns ,
TEFRA
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more
With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules. Under these rules, the default is that the...more
Holland & Knight invites you to read our China Practice Newsletter, in which our authors discuss pertinent Sino-American topics -
HIGHLIGHTS:
Preference Claims
Clawbacks in Bankruptcy Can Disrupt a Construction...more
11/1/2021
/ Audits ,
Bankruptcy Code ,
Bankruptcy Preferences ,
Caremark claim ,
China ,
Clawbacks ,
Commercial Bankruptcy ,
Construction Project ,
Corporate Governance ,
Defense Strategies ,
Diversity ,
Diversity and Inclusion Standards (D&I) ,
IRS ,
Multinationals ,
Nasdaq ,
Offshore Funds ,
Securities and Exchange Commission (SEC)
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more