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
In a significant development for multinational companies operating in the digital space, France’s Supreme Administrative Court (Conseil d’État) has referred the country’s Digital Services Tax (DST) regime to the...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
Filing your 2024-25 Self-Assessment return early means faster refunds, better budgeting, and no deadline stress. Do not delay, start gathering your tax details today....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
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
One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...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
Gross receipts from healthcare services delivered to dialysis patients were properly sourced to Ohio where the treatments were performed. Accordingly, the patients received the benefit of the dialysis services at the...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
A recent Supreme Court of Arkansas decision has upheld a multistate corporation’s allocation to Arkansas of 100% of its interest expenses from borrowings to fund a spin-off. It also rejected as irrelevant the state’s attempt...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
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 1989’s Bill & Ted’s Excellent Adventure, Keanu Reeves plays a stoner who gets caught up in historical shenanigans. By 2014, Mr. Reeves progressed past his teenage high jinks to become a James Bond-like action hero in his...more
In January, we published an article in this newsletter on the state of cannabis taxation, including a discussion of the crippling impact of Internal Revenue Code §280E (IRC §280E) on the industry. Since that article was...more
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
Defendant and his co-conspirators firebombed an informant’s house and killed several individuals. Six weeks into their trial on related charges, the Government disclosed that one of the defense attorneys previously worked as...more
Now that the 2023 tax filing season is underway, many taxpayers are having an unpleasant surprise when they file their tax return this year and find out they are getting a much smaller refund than they were expecting, or...more
The current draft of the Tax Relief for American Families and Workers Act of 2024 includes a proposed provision that would dramatically accelerate the deadline to file claims for the Employee Retention Credit (ERC) to January...more
The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more
A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more
Texas, famously, does not tax individuals’ income, but it does impose franchise taxes on “taxable entities”, such as limited liability companies. Federal tax law treats them as partnerships unless they elect to be treated...more
Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary: Eric Schwartz (“Schwartz”) and his spouse divorced. Pursuant to those divorce proceedings, the state court...more