Alex Cheng-Yi Lee
By Alex Cheng-Yi Lee, Andrew R. Roberson and Kevin Spencer on May 4, 2020
Posted In Appellate Courts, Trial Courts, Uncategorized
On April 24, 2020, the US Court of Appeals for the Eighth Circuit published its opinion in Wells Fargo & Co. v. United States, No. 17-3578, affirming a district court’s holdings that the taxpayer was not entitled to certain foreign tax credits and was liable for the negligence penalty for claiming the credits. Much has...
By Alex Cheng-Yi Lee, Andrew R. Roberson and Kevin Spencer on Apr 17, 2020
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized
On April 14, 2020, the Internal Revenue Service (IRS) issued informal guidance in the form of frequently asked questions (the “FAQs”), urging taxpayers to strengthen their transfer pricing documentation required under Internal Revenue Code (IRC) section 6662(e) and Treasury Regulations § 1.6662-6. IRC section 6662 provides several types of accuracy-related penalties on underpayments of taxes....
By Alex Cheng-Yi Lee, Andrew R. Roberson and Kevin Spencer on Jul 12, 2016
Posted In Court Procedure Matters, Trial Courts, Uncategorized
On July 8, 2016, Judge Buch of the US Tax Court (Tax Court) granted the Internal Revenue Services (IRS) motion to compel depositions of six individuals in Dynamo Holdings Ltd. P’ship v. Commissioner. That case involves the question of whether certain transfers between related entities are disguised gifts or loans. The IRS has been attempting...
IRS Issues New Procedures to IRS Appeals for Requesting Assistance from Exam in Docketed Tax Court Case
By Kevin Spencer, Alex Cheng-Yi Lee, Roger J. Jones and McDermott Will & Emery on Jul 1, 2016
Posted In IRS Appeals, IRS Audits, Transfer Pricing Resource, Uncategorized
On June 24, 2016, the Internal Revenue Service (IRS) issued a memorandum (AP-08-0616-0003, available here) to the IRS Appeals Division (Appeals) providing new, uniform procedures for requesting assistance from the Examination Division (Exam) in docketed Tax Court cases. The guidance implements standard procedures that would treat petitioners similarly. Currently, when petitioners provide new information to...