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Caplin & Drysdale
 
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By Caplin & Drysdale
The IRS intends to issue certifications and decertifications of seriously delinquent tax debts systematically on a weekly basis.
By Kevin Maclay, Todd Phillips, Caroline E. Parke
The parties have jointly moved for a deadline of March 8, 2018 to file for review by the full Ninth Circuit.
By James Wehner, Sally J. Sullivan
Is an increased risk of harm sufficient to establish standing in a data breach case? Most courts have avoided an absolute answer, instead weighing the characteristics of the data breach.
By Douglas Varley, Sharon Want, William Fournier, Meghan R. Biss
The IRS has announced procedural changes that will impact exempt organizations in 2018. These changes concern new organizations and organizations that have lost exemption due to automatic revocation.
By Todd Phillips, Kevin Maclay, Sally J. Sullivan
On September 22, 2017, the First Circuit Court of Appeals held that § 1109(b) of the Bankruptcy Code (the "Code") provides a creditors' committee with an "unconditional right to intervene" in an adversary proceeding.
By Jonathan Brenner, Elizabeth Stevens
The Bipartisan Budget Act of 2015 fundamentally changed the rules by which partnerships, and entities taxed as partnerships (such as limited liability companies), interact with the Internal Revenue Service in an audit or litigation.
By Beth Kaufman, Amanda M. Leon
For many individuals, it will be advantageous to pay bills for nonbusiness tax preparation and tax advice before the end of 2017.
By Victor Jaramillo, Scott D. Michel, Mark D. Allison
What has been ignored is the tax impact and consequences on the players and their families.
By Caplin & Drysdale
The German newspaper Süddeutsche Zeitung and the International Consortium of Investigative Journalists (ICIJ) followed up the release of the "Panama Papers" in 2016 with what they are referring to as the "Paradise Papers."
By Patricia Gimbel Lewis, J. Clark Armitage, Elizabeth Stevens
To protect APA benefits, taxpayers should make a good faith effort to present known facts during the APA process, to comply with the APA, and to correct any non-compliance when discovered.
By Joanne Youn, Ronald Cluett
Nor does the legal analysis end once a plan has satisfied itself that the church plan exemption properly applies.
By Joanne Youn, Ronald Cluett
The OC List provided on the IRS website identifies changes in qualification requirements effective during a calendar year.
By Christopher Rizek, Charles Ruchelman, Rachel Partain, Arianna Caldwell
On November 1, 2016, the Internal Revenue Service ("IRS") issued Notice 2016-66, identifying certain transactions relating to "micro-captive" insurance companies as "transactions of interest."
By Trevor Potter, Matthew Sanderson, Bryson Morgan
This past weekend, President Donald Trump signed an Executive Order requiring all new appointees in his Administration to sign an ethics pledge that contains special "revolving door" and gift restrictions.
By Mark D. Allison, J. Clark Armitage, Kirsten Burmester, Niles Elber, Neal Kochman, Rachel Partain, Charles Ruchelman, James Salles, Zhanna Ziering, Dustin Barzell
On January 31, 2017, the Internal Revenue Service launched its first wave of compliance "campaigns." A campaign is an issue-based compliance process centering on focused examinations, staffed with IRS experts on the targeted subject matter.
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