Jones Day Presents: LB&I Examination Strategies: Process Overview
Podcast: Cum-Ex Dividend Trade Investigations
Supreme Court’s Rulings On Same-Sex Marriage Spark Many Questions On Employee Benefits
On July 25, 2025, the U.S. Court of Appeals for the Eighth Circuit affirmed the District Court decision holding that the Mayo Clinic is entitled to an $11.5 million refund of certain unrelated business income taxes imposed on...more
On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more
Taxpayers who made payments to the Internal Revenue Service (IRS) that included underpayment interest and/or failure-to-file/pay penalties that accrued during all or part of the period between January 20, 2020, through July...more
A recent 1st U.S. Circuit Court of Appeals ruling upheld a lower court decision that the Controlled Substances Act (CSA) does not violate federal law. The decision stems from Canna Provisions’ lawsuit against the government...more
A May 2 report from the US Treasury Inspector General for Tax Administration (TIGTA) found that as of March, the Internal Revenue Service (IRS) workforce had fallen by 11,443 employees, or 11%, due to probationary employee...more
It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more
The federal government is putting paper checks on notice. In an Executive Order (EO) signed on March 25, President Trump directed the Department of the Treasury to stop issuing — and accepting — paper checks for nearly all...more
Join McDermott’s Tax Controversy & Litigation Group for an insightful webinar on the intricacies of claiming and collecting IRS tax refunds. This session is designed for tax professionals, legal practitioners, and anyone...more
On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more
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
The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more
On January 22, 2025, the US Department of Justice (DOJ) announced the indictment of seven individuals in the largest Employee Retention Credit (ERC) fraud scheme to date. According to the indictment, the defendants filed more...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 6, 2025 – January 10, 2025....more
In light of the ongoing wildfires in Los Angeles, we want to take a moment to express our deep concern for all those affected by this devastating disaster. Our thoughts are with everyone impacted by the fires....more
A potential refund opportunity under the Michigan corporate income tax may justify taking action before year end. The issue concerns the Michigan Department of Treasury’s position that the Internal Revenue Code (“IRC”) 163(j)...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024. ...more
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
In Grigsby v. United States, the Justice Department used discovery procedures in federal district court essentially to audit a taxpayer’s federal income tax credits for research activities. The court found that the taxpayer...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28, 2024 – November 1, 2024....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 7, 2024 – October 11, 2024. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 30, 2024 – October 4, 2024....more
A recent spate of mail thefts has left the IRS holding the bag when taxpayer refunds have failed to reach those taxpayers. Congress has begun looking into these thefts. Some have occurred from USPS employee theft, but others...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26, 2024 – August 30, 2024. ...more