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Emily A. Mussio advises clients on various aspects of United States and international tax law. She is experienced with tax controversy and litigation, and federal income tax covering individuals, corporate and partnership taxation. Read Emily Mussio's full bio.

Tax Court Announces Limited Entries of Appearance

By , and on May 29, 2019
Posted In Court Procedure Matters, Uncategorized

The concept of limited scope representation is not a new one in the legal arena. Rule 1.2(c) of the ABA Model Rules of Professional Conduct provides that “A lawyer may limit the scope of the representation if the limitation is reasonable under the circumstances and the client gives informed consent.” This rule has been broadly...

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Tax Reform Insights: IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

By , and on Dec 26, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code) Section 163 by modifying paragraph (j) to limit the amount of business interest a taxpayer may deduct for taxable years beginning after...

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Law360: A Look At Tax Code Section 199’s Last Stand

By , and on Nov 7, 2018
Posted In Alternative Dispute Resolution, Court Procedure Matters, IRS Guidance, Settlements, Tax Reform, Trial Courts, Uncategorized

Andy Roberson, Kevin Spencer and Emily Mussio recently authored an article for Law360 entitled, “A Look At Tax Code Section 199’s Last Stand.” The article discusses the IRS’s contentious history in handling Code Section 199 and the taxpayers’ continued battle to claim the benefit – even after its recent repeal. Access the full article. Originally...

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LB&I Announces Five New Campaigns

By , and on Sep 17, 2018
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized

On September 10, 2018, the Internal Revenue Service (IRS) Large Business and International (LB&I) Division announced five new audit “campaigns.” These new campaigns follow: (1) the initial 13 campaigns announced on January 31, 2017; (2) followed by 11 campaigns announced on November 3, 2017; (3) five campaigns announced on March 13, 2018; six campaigns announced...

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Court Rejects Taxpayer’s Claim for US-Swiss Treaty Coverage

By and on Aug 23, 2017
Posted In Transfer Pricing Resource, Trial Courts, Uncategorized

On August 14, 2017, the United States District Court for the District of Columbia (DC District Court) decided Starr International Company, Inc. v. United States. In Starr International, the DC District Court held that the Internal Revenue Service (IRS) was not arbitrary or capricious in finding at least one of the taxpayer’s principal purposes for...

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Courts Rejects Challenge to OVDP Transition Rules

By and on Jul 18, 2017
Posted In IRS Audits, IRS Guidance, Trial Courts, Uncategorized

The Internal Revenue Service (IRS) currently offers non-compliant US taxpayers several different relief programs to report foreign assets and/or income to become compliant with US rules related to the disclosure of offshore income. See here for a link to the different options. The two main programs are the Offshore Voluntary Disclosure Program (OVDP) and the...

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