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Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

USA - May 26 2021 Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on…

Aaron M. Payne, Ellen McElroy, Mary Kate Nicholson, Michael D. Resnick.

Supreme Court puts IRS on notice [2016-66] in CIC Services, LLC —The Anti-Injunction Act has its limits

USA - May 25 2021 On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge…

Bradley M. Seltzer, Daniel G. Strickland, Ellen McElroy, Graham R. Green, M. Kristan Rizzolo, Mary E. Monahan, Robert S. Chase II, Sarah E. Paul.

No harm, no foul: IRS guidance provides path to claim PPP-related deductions for taxpayers who followed its earlier—but now obsolete—advice

USA - April 30 2021 The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received…

Daniel G. Strickland, Ellen McElroy, Mary Kate Nicholson, Robert Christoffel, Robert S. Chase II.

IRS warns taxpayers using obsolete section 199 deductions

USA - March 4 2021 On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete…

Ellen McElroy, Mary Kate Nicholson, Michael D. Resnick.

IRS updates guidance to reflect legislation on expense deductibility under the PPP

USA - January 12 2021 In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of…

Ellen McElroy, Mary Kate Nicholson, Robert Christoffel, Robert S. Chase II.