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Tax Bytes: Week of July 7, 2025

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

IRS re-commits to pre-filing agreements

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

Congress considers TCJA extenders and Taiwan tax relief

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

Proposed bill aims to postpone TCJA limits on business incentives

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

Rise and shine: IRS and Treasury provide insight on Notice 2023-63 and treatment of R&E expenditures under Section 174

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

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