Comments by IRS officials and government reports reveal that the IRS is heightening its scrutiny of deductions claimed for the charitable contributions of conservation easements under Internal Revenue Code section 170(h). The IRS is devoting increased resources and coordinating the issue on a nationwide basis.

On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion.

To date, a limit on the duration of trusts in the United States has been a rule of property law, governed by state statute or case law, and has varied from state to state.

The Supreme Court in United States v. Windsor declared unconstitutional Section 3 of the Defense of Marriage Act.

The IRS has recently issued Notice 2013-45 postponing until 2015 the information reporting and penalty provisions of the Patient Protection and Affordable Care Act of 2010.

The US Congress enacted the Foreign Account Tax Compliance Act shortly after the first so-called ‘voluntary disclosure program’ had begun to reveal the unanticipated extent of US persons’ undisclosed non-US financial holdings.

Late last year, Congress completely overhauled the rules by which the Internal Revenue Service ("IRS") examines partnerships and limited liability companies ("LLC").

Summer 2018 proved to be an active time in the implementation cycle of the new partnership audit regime, created under the Bipartisan Budget Act of 2015 ("BBA").

In response to the COVID-19 crisis, the Internal Revenue Service (the "Service") has initiated programs to help taxpayers during these difficult times.

The change would alter current practice in the commercial loan market in the case of a U.S. issuer borrowing with credit support from its CFCs.

For most nonprofits, the biggest impact will be the need to keep track of whether they have any employees whose compensation may be subject to the tax.

In an unanticipated development, the IRS posted on its website on September 30, 2008, a new version of Treasury Department Form 90-22.1, named “Report of Foreign Bank and Financial Accounts,” and known as the “FBAR.”

A discussion on the possibility of election reforms.

It is widely expected that Congress will address tax reform early in its 2017 session. This alert summarizes President-Elect Trump's proposal and Speaker of the House Paul Ryan's proposal on key corporate tax provisions . . .

The IRS published final Treasury regulations for two separate information reporting requirements added to the Internal Revenue Code by the PPACA.

Civil examinations and litigations and criminal cases often involve multiple, sometimes related, persons—each of whom might be represented by separate counsel.

On October 12, 2021, the U.S. Supreme Court denied, without comment, a petition for a writ of certiorari in a case challenging the doctrine of equitable mootness.

Isn’t it common sense that in order to be a "resident" of a State one must actually reside in the State? Not so for the State of New York’s taxing authority.

On July 31, the IRS announced in Notice 2012-52 that donors may claim charitable deductions for their contributions to domestic disregarded LLCs that are wholly owned and controlled by U.S. charities.

Effective January 1, 2024, employers who sponsor 401(k), 403(b), or governmental 457(b) plans have a new plan design option to add emergency savings accounts to their existing retirement plans.