REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
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
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
On October 20, 2023, the Internal Revenue Service (IRS) announced new initiatives “to ensure large corporations pay taxes owed.” These initiatives leverage the substantial additional congressional funding that was given to...more
The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more
When we previously wrote about the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS), we explained that the IRS generally must submit proposed refunds in...more
The 2022 discretionary funding request (request) made by the Biden Administration will invest in a “fair and robust” tax system that includes tax compliance enforcement directed at High Income and High Net Worth Individuals...more
Internal Revenue Service (IRS) Commissioner Chuck Rettig on April 13, 2021, told a U.S. Senate panel that the tax gap in the U.S. may total $1 trillion per year. In his view, the increase from prior estimates is due, in part,...more
• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
The Administration’s frenzy to pass “tax reform” created tax breaks for some—I’m looking at you, the Trump family—increased taxes for others, and confusion for everyone, at least until the IRS is able to promulgate official...more
On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more