USA, McDermott Will & Emery updates

Corporate Tax

Contributed by McDermott Will & Emery
Vultures circling as bill to expand CFCA to tax looms in legislature
  • USA
  • 13 September 2019

Legislators in Sacramento are mulling over one of the most (if not the most) troubling state and local tax bills of the past decade. AB 1270, which was recently introduced and passed by the California Assembly in May 2019, would amend the California False Claims Act to remove the 'tax bar' – a prohibition that exists in the federal False Claims Act and the vast majority of states with similar laws.

Tax blog: new Q&A for Section 965
  • USA
  • 02 August 2019

The Internal Revenue Service recently released new informal guidelines regarding Section 965 of the Internal Revenue Code. Among other things, the guidelines contain information on making successive instalment payments, filing transfer agreements as a result of certain acceleration or triggering events and other matters relating to S corporation shareholders making the Section 965(i) election.

Taxpayer First Act: changes to IRS appeals process
  • USA
  • 26 July 2019

The enactment of the Taxpayer First Act brings with it several changes to the procedures and operations of the Internal Revenue Service (IRS). The act touches on (among other things) establishing the IRS Independent Office of Appeals, improving customer service and introducing changes to enforcement. However, it appears that many of the changes to the IRS appeals process are mere guidelines and do not apply to large taxpayers.

Wisconsin enacts discriminatory exit charge for businesses moving out of state
  • USA
  • 19 July 2019

A Wisconsin governor recently signed into law an act that either bars a reduction for, or requires amounts deducted to be added back to, Wisconsin taxable income for moving expenses deducted on federal income tax returns if the expenses are associated with a business moving out of the state or country. However, the act blatantly discriminates against interstate and international commerce and is unconstitutional.

Is an increase in LB&I assertion of penalties on the horizon?
  • USA
  • 05 July 2019

The Treasury Inspector General for Tax Administration recently released a report indicating that changes may be in the works regarding the assertion of accuracy-related penalties in examinations handled by the Internal Revenue Service's large business and international division. The report strongly indicates that large business and international examiners and their supervisors will increase their scrutiny of accuracy-related penalty criteria in examinations.

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