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…
New Group Pricing Structure One of my key goals for the 2025–2026 fiscal year…
Corporate Apportionment of Partnership Income A decision issued by the Virginia Court of Appeals, FJ…
2026 State Tax Changes According to the Tax Foundation, forty-three states made significant changes…
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,…
The Price of Regulatory Certainty Prior to the Inflation Reduction Act (IRA) of 2022, transferability…
Masha Freyvert When Masha Freyvert was an undergraduate at Boston University, she…