Professional Standards
Protecting Privilege in ‘Work From Anywhere’ Era
The move toward remote or hybrid work arrangements is underway and irreversible
Even prior to the COVID-19 pandemic, tax functions were adapting and reacting to fundamental change and uncertainty. Whether the changes were brought about by the Tax Cuts and Jobs Act, by ever more aggressive positions taken by state and local auditors, by complex and burdensome reporting regimes, by novel taxes… Read more »
Sauce for the Goose: Standards Applicable to Taxpayers, Practitioners — and the IRS
The contention among the parties results not from a lack of reasonable standards, but rather from an apparent failure by some IRS personnel to follow those standards in practice and the relative lack of accountability.
The relationship between the Internal Revenue Service’s Large Business & International (LB&I) Division and its constituent taxpayers is complex, marked by alternating episodes of cooperation and contention. LB&I often invites taxpayers and their representative groups to participate in the agency’s critical self-evaluation and listens closely to suggestions and complaints. At… Read more »
Why Unclaimed Property Risk Management Is on the Menu in 2022 Every state has adopted an unclaimed property (or escheat) law,…
Obtaining IRS Refunds: Procedures and Strategies Uncertainty in tax law is reaching unprecedented levels. In the…
The Evolving Landscape of Cross-Border Tax Examination Our clients and our practice group members are increasingly occupied…
Much Ado, but Little New: A Guide to Section 951(a) After Build Back Better The definition of “pro rata share” in Section 951(a)(2) is…
New Frontiers of Dispute Settlement in a Pillar One World—Part One Over the past several decades, the seemingly discrete disciplines of…
TEI Roundtable No. 37: Lessons Learned From TCJA Implementation This roundtable was conducted on October 27 as the closing…