Ask the Experts
The New Partnership Audit Rules
The Expert: Kathryn Keneally
The Bipartisan Budget Act of 2015, signed into law November 2, 2015, repealed the long-standing audit and litigation procedures for partnerships that had been enacted in the Tax Equity and Fiscal Responsibility Act of 1982 and created a statutory framework for new partnership audit rules. The new partnership audit rules… Read more »
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… Read more »
Canadian Tax Collection Provisions
The Expert: Blake Murray
A Canadian income tax assessment or GST/HST assessment triggers an immediate payment obligation and is subject to collection action by the Canada Revenue Agency (CRA), notwithstanding that the taxpayer is formally disputing the assessed amounts. It is important for taxpayers facing large Canadian tax assessments or negotiating indemnification provisions in respect… Read more »
IRS Interviews
The Experts: Jeffrey Friedman and Jessica Kerner
The Washington State Senate recently introduced a bill that would create an independent forum for hearing state tax appeals. This proposal follows the recent creation of the Alabama Tax Tribunal, the Illinois Independent Tax Tribunal, and the Georgia Tax Tribunal. These new tribunals represent significant changes that are improving the… Read more »
Sales Tax Traps for Disregarded Entities Sales tax rules can be confusing, because states often take…
Overreliance on AI for Tax Advice: A Cautionary Perspective With the increasing popularity of artificial intelligence (AI), many people…
Considerations in Tax Refund Litigation The Internal Revenue Service has seen unprecedented changes this year.…
TEI Tax Technology Seminar Set to Deliver Once Again Each year, TEI’s Tax Technology Seminar brings together in-house tax…
The Unconstitutionality of the Brazilian QDMTT On December 30, 2024, the government of Brazil published Law…
How Is Tax Policy Shaping the Future of Clean Energy Investment? US electricity demand is accelerating at a pace few anticipated.…