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  Justin Jesse focuses his practice on US and international tax and tax controversy. He advises clients on all aspects of tax disputes, including cases before the US Tax Court, US district courts and the Internal Revenue Service (IRS). Such matters have included disputes relating to captive insurance, research and development credits, transfer pricing and tax advantaged transactions. He has also represented clients before Congress relating to investigations of tax-related matters. Read Justin Jesse's full bio.

Final Section 468A Regulations Issued at Last


By , and on Sep 11, 2020
Posted In IRS Guidance, Tax Reform

On September 4, 2020, the Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) published in the Federal Register final regulations under section 468A of the Internal Revenue Code (the Code) that address three issues raised by the nuclear electric industry concerning qualified nuclear decommissioning funds (“qualified funds”). These final regulations conclude a many...

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IRS Postpones Virtually All Deadlines Until July 15, 2020, in Response to COVID-19


By , , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

In Notice 2020-23, the Internal Revenue Service further expanded relief for taxpayers in response to the Coronavirus (COVID-19) pandemic. Individuals, corporations, trusts, estates and other taxpayers that ordinarily would have had a filing, payment or other deadline between April 1, 2020, and July 15, 2020, now qualify for an extension. Access the full article.

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CARES Act Refund Claim Guidance


By , and on Apr 10, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

The Coronavirus Aid, Relief and Economic Security Act, or CARES Act, provides tax relief to taxpayers in certain situations. Some of these provisions may generate refunds for prior years, such as the relaxation of restrictions on the use of net operating losses (NOLs) and interest deductions as well as the retroactive availability of additional depreciation...

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IRS to Temporarily Adjust Operations and Key Compliance Functions


By and on Mar 26, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On March 25, 2020, the Internal Revenue Service (IRS) announced a new People First Initiative designed to provide relief to taxpayers on a variety of issues ranging from easing payment guidelines to postponing compliance actions in light of the challenges caused by the Coronavirus (COVID-19) pandemic. The initiative’s projected start date is April 1, 2020, and it...

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IRS Provides Some Relief from Tax Payment (But Not Filing) Deadlines Due to COVID-19


By , , and on Mar 19, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump issued an emergency declaration that directed Secretary Mnuchin to provide appropriate relief from tax payment deadlines to Americans who have been adversely affected by the COVID-19 pandemic. In response to this direction, the IRS issued Notice 2020-17. The Notice declares that all taxpayers have been affected by the emergency...

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The Tax Impact of Recent Federal Actions Relating to COVID-19


By , and on Mar 18, 2020
Posted In IRS Guidance, Uncategorized

On March 13, 2020, President Trump signed a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak under the Robert T. Stafford Disaster Relief and Emergency Assistance Act (the “Stafford Act”). By invoking the Stafford Act, the President provides the Internal Revenue Service (IRS) and US Department of the Treasury (the...

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Senate Passes Tax Extenders Deal That Includes Extension of Renewable Energy Incentives


By , , and on Dec 19, 2019
Posted In Uncategorized

The US Senate today passed a package of tax extenders as part of the year-end appropriations act that the US House of Representatives passed on December 17, 2019. President Trump is expected to sign the legislation before the end of the day tomorrow to avoid a government shutdown. The package includes a one-year extension of...

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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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Maintaining Confidentiality While Navigating Cross-Border Transactions


By , , and on Dec 14, 2017
Posted In IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Uncategorized

Today, taxing authorities across the globe, including the Internal Revenue Service (IRS), are increasing their efforts to gather and share sensitive taxpayer information, often aggressively seeking copies of tax advice, opinions and analysis prepared by counsel and other advisors. In some situations, tax advisors specifically draft their advice to be shared with third parties, but...

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CbC Reporting Is Here to Stay! Treasury Issues Final Regs


By and on Jun 30, 2016
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized

As anticipated in our earlier post, Country-by-Country (CbC) reporting is finally here! On Wednesday, the US Department of the Treasury released final regulations for CbC reporting, effective June 30, 2016. The final regulations apply to any US person who is the “ultimate parent” of a multinational enterprise group that has annual revenue for the preceding year...

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