Kevin Spencer

White & Case LLP

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Goodbye to the IRS AOF Information Document Request

On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance announcing changes to the Large Business & International Division ("LB&I") audit procedures (see the IRS's memorandum, here). The changes aim to...more

7/30/2025 / Audits , Compliance , Dispute Resolution , Information Requests , IRS , Settlement , Tax Planning

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

6/24/2025 / Dispute Resolution , IRS , Large Business & International Division (LB&I) , New Guidance , Revenue Procedures , Tax Credits , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

The IRS Continues Winning Self-Employment Contributions Act (SECA) Tax Against Limited Partners in Private Equity and Hedge Funds

Recently, the Internal Revenue Service ("IRS") has successfully asserted that limited partners in private equity and hedge funds that are organized as limited partnerships were subject to tax under the Self-Employment...more

6/5/2025 / Appeals , Income Taxes , Investment Funds , IRS , Limited Partnerships , Partnerships , Private Equity , Self-Employment Tax , Tax Court , Tax Liability

Mexican Tax Authority (SAT) Substantially Increases Transfer Pricing Tax Collections

On May 26, 2025, the Mexican Tax Administration Service (SAT) reported a 367% increase in tax revenue from large multinationals audits resulting from enforcing Mexico's transfer pricing rules. From 2019 through 2024, the...more

5/30/2025 / Audits , Corporate Taxes , Enforcement , Government Agencies , Income Taxes , International Tax Issues , Mexico , Multinationals , Taxation , Transfer Pricing

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