Kristen Martin

Eversheds Sutherland (US) LLP

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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

7/3/2025 / Audits , Dispute Resolution , International Tax Issues , IRS , Large Business & International Division (LB&I) , Revenue Procedures , Tax Credits , Tax Deductions , Tax Planning , Tax Returns

Government updates procedures to change R&D, income recognition, and inventory methods in new Rev. Proc. 2024-23

On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more

5/13/2024 / Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , Reporting Requirements , Revenue Procedures , Tax Planning , Tax Reform , Tax Refunds , Tax Returns

Sound familiar? IRS releases year-end procedural accounting method guidance regarding the treatment of R&D expenditures under...

Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more

1/2/2024 / Accounting Methods , Corporate Taxes , IRS , New Guidance , Research and Development , Revenue Procedures , Tax Cuts and Jobs Act , Tax Returns , U.S. Treasury

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