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Audits Tax Planning

Morgan Lewis

Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

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Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more

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

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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

Rivkin Radler LLP

Drop & Swap Like-Kind Exchange Passes Muster in New York

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New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...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

Whiteford

Client Alert: Tax Implications of the House v. NCAA Settlement

Whiteford on

The approval of the House v. NCAA settlement marks a watershed moment in college athletics. In addition to $2.8 billion in back damages to former athletes unable to capitalize on the sale of their name, image, and likeness...more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

McDermott Will & Emery

Family Office Symposium 2025 | Key Takeaways

McDermott’s Family Office Symposium 2025 brought together more than 400 single-family office executives and industry leaders to uncover new opportunities, exchange best practices, and strengthen relationships. Focused on the...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Lippes Mathias LLP

Where's My Employee Retention Credit?

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In the years since COVID-19 shut down the country, many businesses applied for the Congressionally-authorized Employee Retention Credit (ERC), a valuable relief program created during the pandemic to support businesses who...more

Foley Hoag LLP

Recent Updates on the Applicability of IRC Section 280E to Cannabis Companies

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Cannabis companies are increasingly taking non-280E positions on their current year federal income tax returns, while many, such as public “MSOs,” have amended prior years’ returns to reflect this position. Foley Hoag’s Tax...more

Allen Barron, Inc.

When Do You Need a Tax Attorney

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One of the most important indications of when you need a tax attorney is any dispute with or contact from the IRS or any California tax agency. This is especially true if the matter involves an audit (or questions regarding...more

IR Global

Accountants Advising on Ownership Structure

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An Accountant based in Atlanta, Georgia provided valuable advice to a new Client who was starting a kitchen design business with a business partner....more

Fox Rothschild LLP

IRS Layoffs May Mean Longer Waits, Audit Delays and Tax Court Battles

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The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025 Special Tax Edition

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Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more

Williams Mullen

[Event] 2025 Winter Tax Forum - February 6th, Richmond, VA

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Join Williams Mullen for our hybrid 2025 Winter Tax Forum on Thursday, February 6th. Our speakers, Anna Derewenda, Kyle Wingfield, Kevin Bender, and Patrick Carr will provide an update on the following: - New Basis...more

Kilpatrick

3 Key Takeaways | Update on Chicagoland Local Taxes

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Kilpatrick’s Samantha Breslow, a partner focusing her practice on state and local tax matters, recently presented to the Illinois State Bar Association on Chicagoland local taxes, including the Chicago Personal Property Lease...more

Kilpatrick

4 Key Takeaways | New York Tax Developments

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On January 16th, Kilpatrick tax partner Jeff Reed presented during a New Jersey Society of CPAs, Bergen County seminar. Jeff discussed recent New York tax developments....more

Freeman Law

Texas Comptroller Procedure | Audits and Assessments

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Receiving an assessment from the Texas Comptroller can be overwhelming, and not just from a financial perspective. To a taxpayer with little to no experience in dealing with the Comptroller’s office, even knowing how to...more

Freeman Law

Centralized Partnership Audit Regime (CPAR) and a Trap for the Unwary

Freeman Law on

Centralized Partnership Audit Regime (CPAR) is a somewhat new regime that followed TEFRA. Congress promulgated CPAR as part of the Bi-partisan Budget Act of 2015. For taxable years beginning in 2018, CPAR is the controlling...more

Latham & Watkins LLP

New IRS Unit Leverages AI to Step Up Partnership Audits; Hundreds of New Inquiries Expected

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The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more

McDermott Will & Emery

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

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The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Cadwalader, Wickersham & Taft LLP

Democrats Propose Mark-to-Market Tax and Increased Audits on High-Net-Worth Individuals

Democrats at both the federal and state levels are proposing a “mark-to-market” tax and legislation that would mandate more audits on high-income taxpayers....more

Morgan Lewis

Beware States Offering Unilateral Advance Pricing Agreements for Transfer Pricing

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As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more

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