Edward L. Froelich
Subscribe to Edward L. Froelich's PostsEdward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries. Read Edward Froelich's full bio.
IRS roundup: June 3 – 17, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Jun 26, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 3, 2025 – June 17, 2025. Commissioner update June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative...
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IRS Roundup May 15 – June 2, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on Jun 5, 2025
Posted In IRS Guidance, Tax Reform, Trial Courts
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025. IRS GUIDANCE May 15, 2025: The IRS issued Notice 2025-29, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) § 417(e)(3), and the...
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IRS Roundup May 2 – May 13, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on May 19, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025. IRS GUIDANCE May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing guidance on the domestic asset/liability percentages and domestic investment yields used by foreign life insurance companies and foreign property and...
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IRS Roundup April 1 – April 17, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney on May 1, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2025 – April 17, 2025. April 4, 2025: The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan...
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IRS Roundup March 15 – March 28, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio, Matthew J. Blaney and Parisa M. Griess on Apr 7, 2025
Posted In IRS Guidance, Tax Reform, Transfer Pricing Resource
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing the April 2025 short-, mid-, and long-term applicable federal rates for purposes of Internal Revenue Code Section 1274(d), as well...
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IRS Roundup February 17 – March 14, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Mar 14, 2025
Posted In IRS Guidance
Check out our summary of recent Internal Revenue Service (IRS) guidance for February 17, 2025 – March 14, 2025. Editors’ note: With the change in presidential administrations, the IRS has undergone significant transition in recent weeks and issued significantly less guidance than normal. We did not publish the IRS Roundup regularly during these weeks as...
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FedEx Defeats Government’s Loper Bright Gambit
By Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Evan Walters on Mar 13, 2025
Posted In Court Procedure Matters, IRS Guidance, Tax Refunds
On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings are earnings from a taxpayer’s profitable related foreign corporations that are offset by losses from other related foreign corporations. FedEx...
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Upcoming Webinar: Defeating IRS Penalties
By Edward L. Froelich, Shawn O’Brien and Michael J. Scarduzio on Feb 25, 2025
Posted In Court Procedure Matters, IRS Audits
The IRS has an extensive set of penalties that it can impose on both corporate and individual taxpayers, and recent audit trends indicate a growing tendency to apply multiple penalties. Join McDermott’s Tax Controversy & Litigation Group on March 5, 2025, for a webinar that will dive into the penalties the IRS may pursue and...
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IRS Roundup February 10 – 14, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Feb 25, 2025
Posted In IRS Guidance, Tax Reform
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS The previous IRS Roundup provided general coverage of the proposed Taxpayer Assistance and Service (TAS) Act. This post highlights Section 310 of the TAS Act, which would...
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IRS Roundup January 20 – 31, 2025
By Evan Walters, Samuel F. Hamer, Edward L. Froelich and Michael J. Scarduzio on Feb 13, 2025
Posted In Court Procedure Matters, IRS Appeals, IRS Guidance, Tax Reform, Tax Refunds
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025. TAX-CONTROVERSY-RELATED DEVELOPMENTS January 22, 2025: The IRS reminded taxpayers that they have rights – outlined in the Taxpayer Bill of Rights – any...
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