We all know the talking points underlying the corporate tax reform provisions in the recent tax legislation. We were told that corporations were taxed at a roughly 35 percent rate, that tax reform would reduce corporate tax liabilities, and that the...
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In recent years, transfer pricing issues have been a major priority for IRS audits. While the IRS has made headlines by bringing a number of big-dollar cases against large multi-nationals, the courts have not been impressed. Within the past few...
December 26, 2017 by Stuart Bassin You have probably heard that one “feature” of the new tax law is its treatment of deductions for state and local taxes. To simplify, under the new law, deductions for state and local taxes (both income and...
October 17, 2017 Today we welcome back guest blogger Stu Bassin for his take on the argument in the Altera case. Stu has blogged with us on several occasions. Because of the importance of the case, we are providing two views of the argument in...
Daily Tax Report Tuesday, October 10, 2017 Tax Audits: A Ban on Outside Lawyers in IRS Audits Is Past Due, Lawyers Say By Alison Bennett The possibility of a Treasury Department proposal to keep private-sector counsel out of tax...
Ex-Arthur Andersen Exec Sues IRS After Tax Shelter Fight By Jimmy Hoover Law360, Washington (August 25, 2017, 5:51 PM EDT) — A onetime executive of defunct accounting firm Arthur Andersen LLP has sued the IRS for legal fees after he fought off...
“Enrolled agents” are tax specialists authorized by the IRS to represent taxpayers in tax disputes in many of the same ways as tax attorneys and CPAs. To obtain an “enrolled agent” designation, an applicant must pass an IRS competency...
Wells Fargo Decision Answers Economic Substance Question Practitioners have debated the parameters of the economic substance doctrine for decades. A recent district court opinion in Wells Fargo & Co. v. United States, No. 09-CV-2764...
Tax Shelters Side Effect of ACA Repeal Could Include Tax Shelters Snapshot Economic substance doctrine change could make pro-tax shelter argument stronger Tax shelter use has been on decline as IRS has gone after “abusive”...
The Sixth Circuit’s Summa Bomb-shell February 24, 2017 We welcome back guest blogger Stu Bassin. Stu is a solo practitioner in Washington, D.C. who specializes in tax controversy work. Today he talks about Summa Holdings v Commissioner,...