News & Analysis as of

Internal Revenue Service Regulatory Requirements Tax Court

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.  
J.S. Held

The Essential Role of Qualified Personal Property Appraisers in Estate and Donation Valuations

J.S. Held on

When purchasing an expensive engagement ring, one would not seek the expertise of a real estate agent. Similarly, when an estate requires an appraisal, it is crucial to engage the appropriate expert for high value personal...more

Morgan Lewis

Private Funds Year in Review: Key Tax Developments That Shaped the Industry in 2024

Morgan Lewis on

In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more

Eversheds Sutherland (US) LLP

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

Eversheds Sutherland (US) LLP

Tax Court update post-Chevron

On November 5, 2024, Judge Goeke of the United States Tax Court issued an order granting the petitioners’ Motion for Reconsideration of Findings (Motion) in Schwarz v. Commissioner. On May 13, 2024, the Tax Court released...more

McDermott Will & Emery

IRS (Belatedly) Strikes Back Against FedEx in Ongoing Foreign Tax Credit Case

McDermott Will & Emery on

FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more

McDermott Will & Emery

Tax Court Rules Limited Partners May Be Subject to Self-Employment Tax

McDermott Will & Emery on

On November 28, 2023, the US Tax Court granted partial summary judgment in favor of the Internal Revenue Service (IRS) in Soroban Capital Partners LP v. Commissioner and held that “limited partners” are defined...more

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