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
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
We once again want to bring to your attention the Internal Revenue Service’s (IRS) new favorite penalty provision: Internal Revenue Code (IRC) Section 6676. We have reported on this provision several times before, but this...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023...more
As many readers may know, Joseph Wilson (“Mr. Wilson”) was the settlor, tax owner, and beneficiary of a foreign trust. By virtue thereof, Mr. Wilson, as a U.S. citizen, had the requirement to file IRS Form 3520 and IRS Form...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more
As previously reported, during the recent legislative session the Alabama Legislature finally resolved the so-called “Moody Issue,” named after the taxpayer victory in Moody v. Alabama Department of Revenue, regarding the...more
There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more
The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more