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Audits Internal Revenue Service Dispute Resolution

Eversheds Sutherland (US) LLP

IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs

On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more

White & Case LLP

Goodbye to the IRS AOF Information Document Request

White & Case LLP on

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

Eversheds Sutherland (US) LLP

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

McDermott Will & Schulte

Key Takeaways | IRS & FTB: Ultra High-Net-Worth Targets, Taxes & Tips

McDermott Will & Schulte on

This session of the Private Client West Cost Forum 2024 explored the current state of audits and tax controversy and shared practical advice to prepare for challenges ahead of a contest with the IRS or Franchise Tax Board...more

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