K. Christy Vouri-Misso K. Christy Vouri-Misso

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  K. Christy Vouri-Misso focuses her practice on all stages of complex federal tax controversies including Internal Revenue Service (IRS) examinations, administrative appeals, voluntary disclosures, and litigation. She has settled multiple tax disputes with IRS legal counsel avoiding costly litigation in court. Read K. Christy Vouri-Misso's full bio.

IRS Announces More LB&I Campaigns!


By , and on Apr 18, 2019
Posted In IRS Audits, IRS Guidance, Uncategorized

The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage, please click here. The most recent set of campaigns were announced on April 16, 2019, bringing the grand total to 53 campaigns since the program’s initial release on January 13, 2017. The IRS...

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IRS Releases Practice Units on Permanent Establishments


By and on Jan 31, 2019
Posted In IRS Audits, IRS Guidance, Uncategorized

On January 29 and 30, 2019, the Internal Revenue Service’s Large Business and International (LB&I) division released new Practice Units on Permanent Establishments, which can be found here and here. Permanent Establishments create taxing nexus for foreign businesses doing business in the United States and for those who have “effectively connected income.” The Practice Units...

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Deference Provided to Regulations When There’s a Drafting Error


By and on Apr 4, 2018
Posted In Tax Reform, Uncategorized

The Tax Act created two new foreign tax credit limitation baskets – one for foreign branch income (new section 904(d)(1)(B)) and one for any amount includible in gross income under section 951A (i.e., GILTI) – however, it failed to amend section 904(d)(2)(H)(i) to reflect these changes to section 904(d)(1). As a result of this oversight,...

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New Proposed Regulations Limit Use of Non-Government Attorneys


By and on Mar 29, 2018
Posted In IRS Audits, IRS Guidance, Uncategorized

On March 28, 2018, the Treasury Department and Internal Revenue Service (IRS) published Proposed Regulation § 301.7601-1(b)(3)(i) and (ii) which permits the IRS to hire outside specialists to assist in determining the correctness of a taxpayer’s tax liability. The Proposed Regulation also contains an exception specifically prohibiting the IRS from hiring outside attorneys to review...

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IRS OVDP Ending | Time Is Now for Coming into US Tax Compliance – Especially for Those with Willfulness Issues


By , and on Mar 16, 2018
Posted In Alternative Dispute Resolution, IRS Audits, IRS Guidance, Settlements, Uncategorized

On March 13, 2018, the Internal Revenue Service (IRS) announced that it will begin ramping down the current Offshore Voluntary Disclosure Program (OVDP) and urged taxpayers with undisclosed foreign assets to apply for the program prior to its close on September 28, 2018. We have previously reported on developments in the OVDP. Access the full article. 

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Multilateral-APA-Like Program to Create International Tax Certainty for Pilot Participants


By and on Feb 5, 2018
Posted In Transfer Pricing Resource, Uncategorized

On January 23, 2018, the International Compliance Assurance Programme (ICAP) was launched at an orientation event in Washington, DC. The ICAP pilot is a voluntary program in which the participants will use country-by-country reporting and other information to establish multilateral agreements in order to establish early tax certainty and assurance. The ICAP handbook can be...

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Nominations Announced for Tax Court and IRS Commissioner


By , and on Jan 24, 2018
Posted In Trial Courts, Uncategorized

On January 23, 2018, President Trump announced his intent to nominate Courtney Dunbar Jones to the US Tax Court. He previously nominated Elizabeth Copeland and Patrick Urda on August 3, 2017. Courtney Dunbar Jones is a senior attorney in the Tax-Exempt and Government Entities division in the Office of Chief Counsel of the Internal Revenue...

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Senior Tax Court Judge Robert A. Wherry, Jr. Retires


By and on Jan 8, 2018
Posted In Court Procedure Matters, Trial Courts, Uncategorized

On January 3, 2018, Chief Judge Marvel of the US Tax Court (Tax Court) announced that Senior Judge Robert A. Wherry, Jr. fully retired as of January 1, 2018, and would no longer be recalled for judicial service. Judge Wherry was appointed on April 23, 2003, by President George W. Bush. In 2014, Judge Wherry...

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Facebook Goes to District Court to Enforce Access to IRS Appeals


By and on Nov 13, 2017
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized

On November 8, 2017, Facebook, Inc. and Subsidiaries (Facebook) filed a complaint in the District Court for the Northern District of California asserting that the Internal Revenue Service (IRS) had improperly denied Facebook access to Internal Revenue Service (IRS) Appeals. Facebook’s complaint seeks a declaratory judgment that the IRS unlawfully issued Revenue Procedure 2016-22, 2016-15...

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Canadian Tax Court Holds that Agreements Reached Under the Mutual Agreement Procedure are Binding on the Canada Revenue Agency


By and on May 9, 2017
Posted In Court Procedure Matters, Transfer Pricing Resource, Trial Courts, Uncategorized

On March 10, 2017, the Tax Court of Canada held that agreements reached under the Mutual Agreement Procedure (MAP) precluded the Canada Revenue Agency (CRA) from redetermining the transfer prices of rock salt sold by Sifto Canada Corp. (Sifto Canada) to a related party in the United States. In 2006, Sifto Canada reevaluated the transfer...

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