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Tax Liability Dispute Resolution

White & Case LLP

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

White & Case LLP on

On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

Husch Blackwell LLP

Nevada Supreme Court Rules Email Constitutes a Written Agreement

Husch Blackwell LLP on

Nevada law requires taxpayers to meet certain prerequisites before seeking judicial review of a Nevada Tax Commission decision. Taxpayers must either pay the amount at dispute or enter into a written agreement with the Nevada...more

Proskauer - Tax Talks

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on

On January 30, 2025, Mike Crapo (R-ID), the Chairman of the Senate Finance Committee, and Senator Ron Wyden (D-OR), the Ranking Member of the Senate Finance Committee released a discussion draft of the “Taxpayer Assistance...more

ArentFox Schiff

Investigations Newsletter: International Mining and Energy Disputes Monitor: 2025 Issue No. 1

ArentFox Schiff on

This inaugural issue of ArentFox Schiff’s publication on international mining, energy, and infrastructure disputes aims to provide insights and practical information to general counsels and senior executives of companies...more

Farrell Fritz, P.C.

Federal Tax Controversies and the Appeals Resolution Process

Farrell Fritz, P.C. on

The Taxpayer First Act (“TFA”), which was signed into law on July 1, 2019, makes the most significant changes to administrative procedures since the Internal Revenue Service Restructuring and Reform Act of 1998. In addition...more

Burr & Forman

IRS Appeals Announces a Return to In-Person Settlement Cases

Burr & Forman on

The IRS and taxpayers often disagree in tax audits and other tax-related matters. The IRS Office of Appeals was established as a separate and independent office within the IRS, whose mission is to resolve these tax disputes,...more

Burr & Forman

The End of an Era: IRS Ends In-Person Settlement Conferences

Burr & Forman on

Taxpayers often have disputes with the IRS, whether through an income tax audit or as a result of actions by IRS officials to collect federal taxes. To resolve these disputes administratively within the IRS, the IRS many...more

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