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US Tax Disputes

Keeping an eye on US tax controversy and litigation developments.

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US Tax Disputes

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IRS Examination Process

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IRS to Begin Hundreds of High-Net-Worth Examinations in July

By Jeff Erney, Mark A. Loyd, Bailey Roese, and Brian Raftery
  • IRS
  • IRS Administration
  • IRS Examination Process
  • LB&I
  • Offshore Reporting
  • Transfer Pricing

IRS Announces 3 More Campaigns for 53 Total

By Jeff Erney
  • IRS
  • IRS Administration
  • IRS Examination Process
  • LB&I
  • Partnerships/TEFRA

IRS Issue BBA Guidance to Office of Appeals

By Jeff Erney
  • FATCA
  • Foreign Tax Credits
  • IRS
  • IRS Administration
  • IRS Examination Process
  • LB&I

IRS Announces Five New Campaigns

By Jeff Erney
  • General
  • IRS
  • IRS Administration
  • IRS Examination Process
  • LB&I

IRS Announces Five New Campaigns

By Jeff Erney
  • Individual Taxation
  • IRS Examination Process
  • Litigation
  • Refund Claims

The Ninth Circuit Holds Equitable Recoupment Not Time-Barred

By Marc Teitelbaum and John Harrington
  • IRS Examination Process
  • IRS Summons
  • Tax Conventions and Treaties

Can the IRS Circumvent U.S. Law by Issuing a Treaty Request?

By Marc Teitelbaum and John Harrington
  • IRS Examination Process
  • Offshore Reporting
  • Voluntary Disclosure

IRS Announces Third Special Offshore Voluntary Disclosure Initiative

By Abraham Piontnica
  • IRS Examination Process
  • Litigation
  • Tax Crimes

“Strategies for Managing Parallel Proceedings with Fifth Amendment Implications,” Inside the Minds: Strategies for Criminal Tax Cases

By Marc Teitelbaum and John Harrington

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