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Internal Revenue Service Administrative Procedure

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Miller Canfield

IRS Fast-Track Settlement Has Been Refined to Improve Accessibility

Miller Canfield on

Taxpayers whose tax returns the IRS examines may experience long administrative delays in working with the IRS to resolve unagreed issues. About twenty years ago, the IRS developed a procedure – fast track settlement – to...more

Dorsey & Whitney LLP

The Supreme Court Update - January 13, 2025

Dorsey & Whitney LLP on

On January 10, 2025, the Supreme Court of the United States granted certiorari in three cases: Becerra v. Braidwood Management, Inc., No. 24-316: This case addresses the constitutionality of the U.S. Preventive Services...more

Harris Beach Murtha PLLC

IRS Issued Simplified Procedures to Resolve Common S Corporation and QSub Errors

Harris Beach Murtha PLLC on

Failure to meet and maintain the requirements to be treated as an S corporation for federal income tax purposes can result in the loss of S corporation status and the resulting loss of pass-through entity tax treatment. ...more

Miller Canfield

Disregarding Administrative Tax Guidance Aided the IRS in Two Cases and the Taxpayer in a Third Case

Miller Canfield on

​​​​​​​Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

Miller Canfield on

Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

Eversheds Sutherland (US) LLP

IRS updates process for FAQs on new tax legislation and addresses taxpayer reliance concerns

On October 15, 2021, the Internal Revenue Service (the IRS or the Service) issued IR-2021-202 that describes the basis upon which taxpayers may rely on frequently asked questions (FAQs) to avoid certain penalties and...more

Holland & Knight LLP

When IRS Penalty Assertions Are Unlawful

Holland & Knight LLP on

One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts (each, a "penalty" and collectively, "penalties"). This should come as no...more

Flaster Greenberg PC

New Retirement Plan Hardship Distribution Rules: What You Need to Know

Flaster Greenberg PC on

The IRS recently amended the rules applicable to hardship distributions from 401(k) and 403(b) plans. The new hardship distribution regulation relaxes some of the restrictions on the availability of hardship distributions...more

White & Case LLP

Taxpayer First Act and the Independent Office of Appeals

White & Case LLP on

The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more

McDermott Will & Emery

What Happens At Exam, Stays At Exam!

McDermott Will & Emery on

A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you...more

BCLP

Group Ruling Holders will no longer receive lists of parent and subsidiary accounts from IRS

BCLP on

As of January 1, 2019, the IRS stopped mailing lists of parent and subsidiary accounts to central organizations (group ruling holders) for verification and return. Central organizations with accounting periods ending June 30,...more

Bricker Graydon LLP

ACA employer mandate penalty letters are on the way

Bricker Graydon LLP on

The IRS has recently taken affirmative steps towards assessing the Affordable Care Act (ACA) employer mandate penalties, which are set to begin before the end of 2017. The agency has updated its website with information...more

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