Professional Standards
Protecting Privilege in ‘Work From Anywhere’ Era
The move toward remote or hybrid work arrangements is underway and irreversible
Even prior to the COVID-19 pandemic, tax functions were adapting and reacting to fundamental change and uncertainty. Whether the changes were brought about by the Tax Cuts and Jobs Act, by ever more aggressive positions taken by state and local auditors, by complex and burdensome reporting regimes, by novel taxes… Read more »
Sauce for the Goose: Standards Applicable to Taxpayers, Practitioners — and the IRS
The contention among the parties results not from a lack of reasonable standards, but rather from an apparent failure by some IRS personnel to follow those standards in practice and the relative lack of accountability.
The relationship between the Internal Revenue Service’s Large Business & International (LB&I) Division and its constituent taxpayers is complex, marked by alternating episodes of cooperation and contention. LB&I often invites taxpayers and their representative groups to participate in the agency’s critical self-evaluation and listens closely to suggestions and complaints. At… Read more »
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
The Supreme Court Ruling and the Potential for Tariff Refunds: Their Impact on Transfer Pricing When the United States introduced reciprocal tariffs in April 2025,…
Overlooked in Tax Transformation: Elevating Notice Management to a Core Compliance Control Tax technology has advanced rapidly, with recent coverage highlighting the…