News & Analysis as of

Tax Liability Settlement

Mayer Brown

Brazilian Internal Revenue Service Publishes New Rules for Low-Value Debts and Debts Up to BRL 50 Million

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On July 7, 2025, the Brazilian Internal Revenue Service (IRS) published Notices No. 4/2025 and No. 5/2025, introducing new modalities of tax settlement by adhesion within the scope of administrative tax litigation, with...more

Mayer Brown

PGDAU Notice No. 11/2025: Tax Settlement for Debt Regularization

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The Brazilian Attorney General's Office of the National Treasury (PGFN) has published PGDAU Notice No. 11/2025 (the “Notice”), which sets forth the conditions for tax settlements to regularize debts up to BRL 45 million...more

Farrell Fritz, P.C.

After the Grievance Deadline: What Commercial Property Owners Should Know About Settlement Season

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The third Tuesday in May marks the end of the Suffolk County, Nassau County and New York City annual grievance filing season and the beginning of administrative hearings and deliberations that could yield significant...more

Offit Kurman

Essentials for Balancing Taxes and Legal Risk

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In this week's episode of OK at Work, attorneys Sarah Sawyer and Russell Berger from Offit Kurman discuss the essentials for balancing taxes and legal risk. They explore how tax considerations play a critical role in various...more

Stikeman Elliott LLP

Tax Court of Canada Denies GST/HST Input Tax Credit Claims in Connection with a Settlement Payment

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In a general procedure hearing that was later moved under the informal procedure rules and rendered on December 17, 2024, the Tax Court of Canada (the “Tax Court”) dismissed 267 O’Connor Limited’s (the “Appellant”) appeal,...more

Foodman CPAs & Advisors

IRS Pilot Mediation Programs

On 1/15/25, the IRS announced three pilot programs to test changes to existing Alternative Dispute Resolution (ADR) programs. The new IRS Pilot Mediation Programs are designed to help taxpayers resolve tax disputes earlier...more

Mayer Brown

Federal Taxes Settlement Program – PGFN and RFB Publish Notices on Debt Settlements

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The Attorney General's Office of the National Treasury (PGFN) and the Brazilian Internal Revenue Service (IRS) published Public Notices No. 25, 26 and 27/2024, within the scope of the Integral Settlement Program, setting...more

Miller Canfield

IRS Fast-Track Settlement Has Been Refined to Improve Accessibility

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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

Mayer Brown

Public Notice No. 6/2024: Tax Settlement for Credits Arising from Charter and Services Agreements

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On May 17, 2024, the Office of the Attorney-General of the National Treasury (“PGFN”) and the Brazilian Internal Revenue Service (“Brazilian IRS”) jointly published the Public Notice of Settlement for Adhesion No. 6/2024...more

Mayer Brown

Public Notice for Adhesion to Tax Settlement: Tax debts Related to Subsidies for Investments

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On May 16, 2024, the Brazilian Internal Revenue Service (“Brazilian IRS”) and the Office of Attorney-General of the National Treasury (“PGFN”) jointly published the Public Notice of Transaction for Adhesion in the Tax...more

Mayer Brown

PGDAU Public Notice No. 2/2024: New tax settlement program for credits up to 45 million reais enrolled into federal overdue tax...

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On May 13, 2024, the Attorney General's Office of the National Treasury published PGDAU Public Notice No. 2/2024, which creates a new tax settlement method for credits enrolled into federal overdue tax liability, with or...more

Freeman Law

[Webinar] Updates: IRS Tax Enforcement, Taxation of Settlements, and Cross-Border Tax Planning - August 31st, 3:00 pm CT

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Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Littler

Tax Court Reiterates the Proper Tax Treatment of “Physical Injuries” in Employment Cases

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In Stassi v. Commissioner, the United States Tax Court found that a settlement was not excludable from income as a personal physical injury because the taxpayer failed to demonstrate that her shingles was caused by her...more

Freeman Law

[Webinar] Freeman Law Legal and Tax Update - October 27th, 3:00 pm CT

Freeman Law on

As businesses face unprecedented challenges, our legal team is here with insights and guidance. Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. During...more

Troutman Pepper

Who Bears Withholding Tax When a Settlement of Litigation Agreement Is Silent?

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IF A SETTLEMENT AGREEMENT IS SILENT, A DEFENDANT IS NOT REQUIRED TO ‘GROSS UP’ THE SETTLEMENT, AND THE PLAINTIFF WILL SUFFER THE WITHHOLDING TAX BURDEN. What happens when settling parties agree that the defendant will...more

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