Tax developments -
IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs -
Significant updates from the IRS Large Business & International (LB&I) Division will take...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more
5/21/2025
/ Business Taxes ,
EBITDA ,
Employee Benefits ,
Employee Retention ,
Excise Tax ,
Legislative Agendas ,
New Legislation ,
Proposed Legislation ,
Reporting Requirements ,
Senate Committees ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Exempt Entities ,
Tax Reform ,
U.S. House ,
Ways and Means Committee
On June 21, 2024, the Internal Revenue Service (IRS) released an early draft of revised Form 6765, Credit for Increasing Research Activities. Following the release of the September 2023 draft Form 6765 which dramatically...more
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more
The Tax Cuts and Jobs Act (TCJA) included a sunset provision for immediate expensing of research and experimentation (R&E) expenditures, generally providing that such expenses would be subject to five-year (domestic R&E) or...more
On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...more