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…
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…