I last provided an update on the proposed regulations under I.R.C. Section 2704 (the 2704 Proposed Regulations) on January 31, 2017, in which I covered President Trump’s then recent Executive...
At last year’s Annual Meadows Collier Tax Conference, my colleague, Stephen Beck, and I discussed some of the more recent hot topics in international tax law. During our discussions, we spoke of the current ambiguity in...
The RESPECT Act (H.R. 1843), also known as the Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act, was originally introduced in the House of Representatives in March 2017....
On Friday, July 7th, the U.S. Department of the Treasury (the “Treasury”) announced in Notice 2017-38 that it is targeting eight tax regulations for potential repeal (click here). Included in the eight targeted are the...
In a previous blog (here), we discussed some suggestions for representing taxpayers in a IRS examination. In this blog, we discuss the next step, i.e., when the exam cannot be resolved and you must make a request for review...
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