Bradford E. LaBonte
By Bradford E. LaBonte, Lowell D. Yoder and Timothy S. Shuman on Nov 20, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized
On October 31, 2018, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released proposed regulations (REG-114540-18) (the Proposed Regulations) that would prevent, in many cases, income inclusions for corporate US shareholders of controlled foreign corporations (CFCs) under section 956. As a result, among other considerations, the Proposed Regulations could significantly expand...
By Bradford E. LaBonte and Kevin Spencer on Feb 2, 2017
Posted In Court Procedure Matters, IRS Appeals, IRS Audits, Transfer Pricing Resource, Trial Courts, Uncategorized
On January 30, 2017, the Internal Revenue Service (IRS) released an International Practice Unit (IPU) on the use of a summons under IRC Section 6038A (IRC Section 6038A Summons) when a US corporation is 25-percent owned by a foreign shareholder. See IPU here. The IPU describes the steps that the IRS should take when issuing...
By Kevin Spencer, Jean A. Pawlow, Bradford E. LaBonte, McDermott Will & Emery, Robin L. Greenhouse and McDermott Will & Emery on Sep 22, 2016
Posted In IRS Appeals, IRS Guidance, Settlements, Uncategorized
The Internal Revenue Service (IRS) has revised the Internal Revenue Manual (IRM) regarding Appeals Conferences. Below is a summary of material changes to IRM 8.6.1, effective October 1, 2016: The IRM was revised to reflect that most conferences in Appeals will be conducted by telephone. The revision also provides guidance for when in-person conferences are appropriate...