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IRS Issues Interim Guidance Eliminating the Acknowledgement of Facts and Expanding Access To Dispute Resolution Programs

The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more

A New Chapter for Clean Energy: Final ITC Regulations Unveiled

On December 4, 2024, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (T.D. 10015) related to the energy credit under Section 48 of the Internal Revenue Code. These...more

Property Owned by Non-Indians and Located on Tribal Land Is Subject to Property Tax

Generally, tribal lands held in trust by the federal government are exempt from state and local taxation under Section 5 of the Indian Reorganization Act of 1934 (the Act). However, when non-Indians are involved in ownership...more

Arizona Taxation of Tribal Work Performed Under Federal Contracts Upheld by U.S. Supreme Court Precedent

A three-panel Arizona Court of Appeals ("the panel”) unanimously ruled on January 10, 2023, that, under U.S. Supreme Court precedent, the gross proceeds from work performed under federal contracts on Native American...more

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