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
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
The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more
6/21/2019
/ Administrative Appeals ,
Administrative Procedure ,
Administrative Procedure Act ,
Due Process ,
Impartiality ,
IRS ,
IRS Independent Office of Appeals ,
Pending Legislation ,
Right To Appeal ,
Tax Appeals ,
Tax Reform ,
Taxpayer First Act of 2019 (TFA) ,
Trump Administration