The IRS continues to expand its enforcement activities, announcing a new compliance campaign to examine large businesses with issues arising out of the TCJA and CARES Act.
The IRS Large Business and International ("LB&I")...more
The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more
7/13/2020
/ Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
High Net-Worth ,
IRS ,
Partnerships ,
Private Foundations ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Trusts ,
Wealth Management
In the fifth installment of Jones Day's series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS's new fast track...more
In the fourth installment of Jones Day’s series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS’s new process...more
In the third in a series of Jones Day’s video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains the Acknowledgment of Facts IDR, and...more
In the second installment of Jones Day’s video series on the IRS's Large Business & International Division ("LB&I") exam process, partner and tax litigator Chuck Hodges discusses changes in how the division issues Information...more
In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more
6/20/2019
/ Examiners ,
Income Taxes ,
Information Document Requests ,
IRS ,
Large Business & International Division (LB&I) ,
Tax Audits ,
Tax Liability ,
Tax Litigation ,
Tax Refunds ,
Tax Returns ,
Transparency
In this installment of Jones Day's continuing series of videos focusing on tax disputes, partner and tax litigator Chuck Hodges explains the Appeals Judicial Approach and Culture ("AJAC") Project's rules and procedures and...more
The appeals process remains a critical component in resolving tax disputes with the U.S. federal government. As such, the IRS introduced the Appeals Judicial Approach and Culture ("AJAC") Project to introduce a quasi-judicial...more
This video is the final in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage four - going to court. He describes the three courts available to taxpayers when they...more
This video is the third in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage three - the IRS post-appeal mediation process, in which the taxpayer and appeals...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
This video is the first in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage one - planning for and handling the IRS examination. He emphasizes the importance of...more