News & Analysis as of

Large Business & International Division (LB&I) Internal Revenue Service Appeals

Snell & Wilmer

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

Snell & Wilmer on

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

McDermott Will & Schulte

IRS Chief Counsel Signals Increased Tax Enforcement

The Internal Revenue Service (IRS) Chief Counsel is the chief legal advisor to the Commissioner of Internal Revenue on all matters pertaining to the interpretation, administration and enforcement of the Internal Revenue Laws....more

McDermott Will & Schulte

IRS Provides Guidance to LB&I Examiners on Requesting Participation in Appeals Conferences

McDermott Will & Schulte on

We recently covered the Appeals Team Case Leader Conferencing Initiative: Summary of Findings and Next Steps (Appeals Summary) in relation to the participation of Large Business & International (LB&I) exam teams and Internal...more

McDermott Will & Schulte

Weekly IRS Roundup October 4 – October 8, 2021

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 4, 2021 – October 8, 2021... October 4, 2021: The IRS released a practice unit,...more

Holland & Knight LLP

When Is a Tax Return "Filed"?

Holland & Knight LLP on

In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

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