Ask the Experts

Elevating Examination Concerns Within the New LB&I
The Expert: Rosemary Sereti

For contentious U.S. federal tax issues, tax controversy management tends to follow a horizontal path from examination to appeals and finally litigation. The likelihood of being embroiled in a contentious issue increased recently as the Internal Revenue Service’s Large Business & International (LB&I) Division announced another round of campaigns. Campaign… Read more »

An End-of-Examination Checklist
The Expert: S. Starling Marshall

Nearing the end of an Internal Revenue Service exam cycle can feel like time to wrap up the process quickly and move on to the next task and then the next cycle. However, considering a few things to do now can result in a faster, more successful resolution of issues… Read more »

State Tax Matters for Foreign Corporations
The Experts: Maria Todorova and Eric J. Coffill

The Experts: Maria Todorova and Eric J. Coffill Even though state taxation has moved away from the worldwide unitary method, with Alaska being the only state currently requiring use of the worldwide unitary method and only then regarding oil and gas corporations, there are still many situations where non-U.S. companies… Read more »

Practical Implications of New Partnership Audit Rules
The Experts: Michael Hauswirth, Todd McArthur, and Adam Feuerstein

Ignore the new partnership audit rules at your own peril. Absent an election of earlier application, they take effect for tax years beginning in 2018. Under the new rules, the Internal Revenue Service (IRS) generally will collect tax at the partnership level on adjusted partnership items at the highest corporate… Read more »

Tax Reformers Consider Cash Flow Business Taxes, VATs, and Integration
The Expert: Harry L. (Hank) Gutman

In the last Congress, tax reformers considered cash flow business taxes, VATs, and integration as part of potential business tax reform. What’s the Outlook for Congressional Tax Reform? The second session of the last Congress saw some positive developments in the seemingly never- ending quest for business income tax reform.… Read more »

The New Partnership Audit Rules
The Expert: Kathryn Keneally

The Bipartisan Budget Act of 2015, signed into law November 2, 2015, repealed the long-standing audit and litigation procedures for partnerships that had been enacted in the Tax Equity and Fiscal Responsibility Act of 1982 and created a statutory framework for new partnership audit rules. The new partnership audit rules… Read more »

The IRS, Privilege, and Transparency
The Experts: Todd Welty, Mark Thomas, and Kevin Spencer

The IRS has imposed increasing disclosure demands on large, multinational taxpayers, requesting filing of a slew of additional documents and forms. Question: How will the Schaeffler case affect the IRS’ ability to require additional disclosure documents from taxpayers? Answer: In the last decade, the Internal Revenue Service (IRS) has shifted… Read more »

Canadian Tax Collection Provisions
The Expert: Blake Murray

A Canadian income tax assessment or GST/HST assessment triggers an immediate payment obligation and is subject to collection action by the Canada Revenue Agency (CRA), notwithstanding that the taxpayer is formally disputing the assessed amounts. It is important for taxpayers facing large Canadian tax assessments or negotiating indemnification provisions in respect… Read more »

IRS Interviews
The Experts: Jeffrey Friedman and Jessica Kerner

The Washington State Senate recently introduced a bill that would create an independent forum for hearing state tax appeals. This proposal follows the recent creation of the Alabama Tax Tribunal, the Illinois Independent Tax Tribunal, and the Georgia Tax Tribunal. These new tribunals represent significant changes that are improving the… Read more »

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