Ask the Experts
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 »
Are Tax Insurance Proceeds Taxable? Tax insurance has emerged as a cornerstone of corporate tax…
OBBBA Modifications to US Taxation of International Income The One Big Beautiful Bill Act (OBBBA), which was signed…
How Does Conformity Impact State Revenues After the OBBBA? State conformity with the Internal Revenue Code (IRC) refers to…
Are Research Credit Interviews and Write-Ups Obsolete? Upon joining a Big Four firm in Washington, D.C.—then known…
Janelle Gabbianelli According to Janelle Gabbianelli, her first job was the catalyst…
Why Co-Sourcing Tax Technology Is Your Best Bet In today’s complex regulatory landscape, tax departments are being pushed…