Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Videocast: SALT Scoreboard – 2019 year in review
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
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 IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Overview of IRS Appeals Judicial Approach & Culture Project (AJAC)
Jones Day Presents: Strategies for Dealing with the IRS: Alternative Dispute Resolution
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
La Cour administrative d'appel de Paris rappelle à l'administration fiscale son obligation de motivation de la réponse aux observations du contribuable sous peine d'entacher la procédure d'irrégularité (CAA Paris, 13 février...more
Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more
Perfection is often an admirable goal, but rarely achieved. However, in the current environment, failure to collect, report and remit your taxes perfectly, particularly in the sales and use tax arena, can leave a taxpayer...more
El 6/20/24, el IRS emitió el Consejo Fiscal 2024-59 para alertar a los contribuyentes que la mediación con el IRS puede ayudarlos a resolver sus problemas tributarios de manera temprana y efectiva. El IRS afirma que la...more
On 6/20/24, the IRS issued Tax Tip 2024-59 to alert taxpayers that mediation with the IRS can assist taxpayers to solve their tax issues early and effectively. IRS states that mediation with the IRS can be a more...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
Join Williams Mullen for our Fall Tax Forum on Thursday, November 9, 2023. Our speaker, Kyle Wingfield, will provide an annual review of Virginia tax developments, including key court decisions, administrative rulings, and...more
An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more
Short Summary. Decedent was a wealthy lawyer and investor. During the last few years of his life, decedent paid significant sums to one of his daughters, one of his stepdaughters, and multiple women with whom he was either...more
I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more
The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more
In the new episode of our tax podcast, “GILTI Conscience,” Fred Goldberg shares insights from his illustrious five-decade career in tax law, from his time as a junior associate through his service as the commissioner of the...more
You are invited to a Freeman Law webinar - 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...more
The IRS, Taxpayers, and Cryptocurrencies or virtual currencies - The Internal Revenue Service (“IRS”) issued its first guidance on cryptocurrencies— “virtual currencies''—in 2014, taking the position that crypto...more
Please join us for the Winter Tax Forum virtually on Wednesday, January 26. Register here to join Farhad Aghdami and Anna Derewenda as they deliver recent tax and wealth planning updates. The two will specifically touch on: ...more
Due to the complexity of Canadian tax law, it is not uncommon for taxpayers and the minister of national revenue to refine their respective positions and identify new arguments and issues in the course of the tax dispute...more
Matt Hunsaker breaks down the latest state tax news including a discussion of tax arguments in a controversial civil war era statue removal case, the Texas Supreme Court's decision to hear Sirius XM's apportionment case, and...more
The OSBA Sales/Use Tax Subcommittee Report discusses recent developments concerning the scope of taxable services, as well as the federal preemption of taxation on internet services which were previously taxable in Ohio....more
In this week's episode, Mike Semes joins Matt Hunsaker in the studio to discuss alternative apportionment and an unfortunate case coming out of Maryland....more
Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more
Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more
In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more