US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

Functional Analysis Over Formalism: Soroban and the SECA Exception for Passive Limited Partners

By Ross Cohen, Stephanie Bruns, Caitlin Rieser, and Lucy McAfee

July 8, 2025

IRS

Latest Posts

IRS

Tax-Efficient Ways to Structure Fund Manager Compensation

By Ross Cohen, Caitlin Rieser, and Lucy McAfee

IRS

Planning for taxes on personal injury judgments

By Stephanie Bruns, Collier Clay, Helen Cooper, Mark A. Loyd, and Lucy McAfee

6th Circuit Rejects Challenge to Commercial Fee Scale for Kentucky Open Record Requests

By Mark A. Loyd, Helen Cooper, Stephanie Bruns, and Collier Clay

Kentucky’s Local Restaurant Taxes

By Mark A. Loyd, Bailey Roese, Helen Cooper, and Stephanie Bruns

General
IRS

IRS AOD 2024‑01: Relief for Taxpayers Facing § 6707A Penalties

By Gregory Rhodes, Mark A. Loyd, Sidney Jackson, Helen Cooper, and Benjamin Strong

General
IRS

JUSTICES’ CERTIORARI DENIAL LEAVES INTERSTATE TAX QUESTIONS

By Mark A. Loyd, Helen Cooper, and Lucy McAfee

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