Tax Reform, Appeals, Tax Court

Taxpayer Assistance and Service Act – Comments from the ABA Tax Section

Baker Botts L.L.P. on 5/20/2025

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a taxpayer-friendly legislative proposal. While it is uncertain whether the TAS Act...more

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on 3/14/2025

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Senators Crapo and Wyden Release Draft Bipartisan Taxpayer Rights Legislation

Proskauer - Tax Talks on 3/3/2025

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

IRS Roundup February 10 – 14, 2025

McDermott Will & Schulte on 2/26/2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS - The previous IRS...more

Something old and something new: Final Appeals regulations maintain pre-TFA exclusions from Appeals eligibility; pilot program...

Eversheds Sutherland (US) LLP on 1/27/2025

On January 14, 2025, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (T.D. 10030) implementing section 7803(e) of the Internal Revenue Code. Section 7803(e) was...more

GST/HST Input Tax Credit Claims: Does the Supporting Documentation Need to be Issued by the Supplier?

Stikeman Elliott LLP on 6/30/2022

On June 9, 2022, the Tax Court of Canada (“TCC”) allowed CFI Funding Trust’s (“CFI”) appeal in relation with the input tax credits (“ITC”) it claimed for prepaid rent paid in connection with the securitization of automobile...more

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

McDermott Will & Schulte on 4/16/2019

Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

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