Drew Cummings

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Latest Posts › Internal Revenue Code (IRC)

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Treasury and IRS Promulgate Final Regulations Governing Resolution of Federal Tax Controversies by the Independent Office of...

The US Department of the Treasury and the Internal Revenue Service (IRS) have released Final Regulations related to the resolution of federal tax controversies by the Independent Office of Appeals (Appeals), largely rejecting...more

2/28/2025 / Appeals , Income Taxes , Internal Revenue Code (IRC) , IRS , New Regulations , Tax Liability , Tax Planning , U.S. Treasury

Expert Testimony May Be Limited if ‘Confidential’ Information Is Withheld Under Section 6103

Expert witnesses can be critical to defending a tax position—but what happens when an expert must maintain confidentiality over information that is important to their analysis? Preserving this confidentiality while ensuring a...more

2/6/2025 / Confidential Communications , Discovery , Evidence , Expert Testimony , Federal Rules of Civil Procedure , Federal Rules of Evidence , Internal Revenue Code (IRC) , IRS , Litigation Strategies , Transfer Pricing

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

1/17/2025 / Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , OECD , Tax Liability , Tax Planning , U.S. Treasury

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