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…

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…

