Nick S. Pegelow explores the risks partnerships face under the Bipartisan Budget Act (BBA)'s Centralized Partnership Audit Regime, and highlights the role of Partnership Representatives.
Nick S. Pegelow unpacks the important expansion of the IRS's disaster relief powers that could provide a lifeline to taxpayers impacted by state-declare emergencies.
In our latest blog post, Nick S. Pegelow examines Yum! Brands' high-stakes case regarding "Killer B" anti-abuse regulations, international reorganizations and when a "B Reorg" triggers a US tax bill.
Taxpayers should try to claim tax refunds within the statute of limitations. Sometimes they can't. Taxpayers under audit, for instance, might have a contingent claim that won't be ripe until the audit concludes. In these situations, a seasoned tax advisor will likely recommend submitting a protective claim for refund, safeguarding the statute of limitations. But if it is too late to file a protective claim, there are still avenues for taxpayers to claim a refund.
A Private Letter Ruling is as close as you can get to certainty in the tax world. That's why the IRS charges up to $43,700 just to look at one. But so long as you don't misrepresent the facts, a PLR is a binding interpretation of current law on both the IRS and the courts. A favorable ruling can reduce tax-return disclosures and FIN 48 adjustments included in applicable financial statements, among other benefits.
Amending tax returns is a necessary evil—sometimes. Correcting a return to add $15,000 of unreported income might not make sense to taxpayers if it costs $25,000 to amend, putting aside ethical and other considerations. But suppose it's an issue with an improper method of accounting.
