Articles: 1-10 of 258
Back in Business? The IRS Revives “Significant Issue” Rulings for Corporate Transactions
USA - May 19 2026 On May 5, 2026, the Internal Revenue Service (“IRS”) released Revenue Procedure 2026-21 (the “Rev. Proc.”), which reinstates a program under which…
In Liberty Global, the Tenth Circuit Leaves Taxpayers with an Opinion with Unresolved Questions
USA - May 11 2026 On April 21, 2026, in Liberty Global, Inc. v. United States, the Tenth Circuit held that the economic substance doctrine was “relevant” and applied…
Court of Appeal confirms genuine EBT loans not taxable as earnings (pre-disguised remuneration rules)
United Kingdom, USA - May 11 2026 The Court of Appeal has confirmed in HMRC v M R Currell Ltd that, prior to the introduction of the disguised remuneration rules, a genuine and…
Burlington in the Court of Appeal: New Guidance on Purpose Tests and Access to Treaty Benefits
United Kingdom - May 5 2026 The Court of Appeal has confirmed in Burlington Loan Management DAC v HMRC that “obtaining the benefit of” a tax treaty is not the same as “taking…
Update: Federal Rulings Ease COVID‑Era Interest, Penalty and Filing Burdens
USA - May 1 2026 Update: The National Taxpayer Advocate has published a blog post urging taxpayers to evaluate whether they have claims for refund based on the recent…
Tax Court Rejects Due Process Challenge to BBA Audit Regime in Jones Bluff
USA - April 14 2026 On March 19, 2026, in Jones Bluff, LLC v. Commissioner, 166 T.C. No. 6 (2026), the Tax Court held that a partnership could not assert due process…
HMRC proposes expanded reporting for close company shareholder transactions
United Kingdom - March 23 2026 Many of our clients and readers will be familiar with the “loan to participator” rules. These rules apply to loans made by close companies, which in…
When a Misdirected Partnership Notice isn’t Fatal under the BBA: Mammoth Cave Property
USA - March 20 2026 Although many of the procedural rules for auditing partnerships at the federal level have changed under the Bipartisan Budget Act of 2015 (the “BBA”)…
Federal Rulings Ease COVID‑Era Interest, Penalty and Filing Burdens
USA - February 27 2026 Relief from underpayment interest, failure-to-file penalties, and failure-to-pay penalties—as well as relief from IRS filing deadlines that arose…
Recent Federal Privilege Ruling Related to AI Tools Has Implications for Routine Tax Advisor Arrangements
USA - February 20 2026 On February 10, 2026, Judge Jed Rakoff of the Southern District of New York ruled in United States v. Heppner that documents generated through a…
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