Wrapping Up May – and Looking Forward to June

Top May Posts You Might Have Missed

LB&I Announces Six New Campaigns

SOL and the 1603 Cash Grant – File Now or Forever Hold Your Peace

IRS Implementation of Tax Reform Continues to Move Forward

Upcoming Tax Controversy Activities in June

Our lawyers will present on key tax topics during the month of June. We hope to see you.

June 21, 2018: Britt Haxton, Kristen Hazel, Enrica Ma, Jane May, Sandra McGill, Alysse McLoughlin, Maureen O’Brien and Diann Smith are presenting at Tax in the City® New York about the various impacts of tax reform on state and local taxes, on digital commerce, on cross-border transactions, and on compensation structures and fringe benefits, along with a CLE/CPE session on the ethical considerations around tax reform. Email Maria Dubinets at mdubinets@mwe.com to register.

June 21, 2018: Todd Welty is presenting a tax court update as part of the “Tax Compliance and Enforcement Update Part I” panel at the New York University Tax Controversy Forum in New York, NY.

Chambers USA released its 2018 edition of annual rankings of law firms and lawyers in various practice areas. We are honored that Chambers USA has recognized McDermott’s tax practice and several of its lawyers in the latest rankings. A summary of McDermott’s tax rankings is listed below along with a complete list available here to all McDermott rankings.

On the tax controversy side, our team was recognized as known for a “Dominant presence in high-value tax disputes across the USA, fielding particular expertise in transfer pricing litigation and SALT work.” Clients said we are “very responsive and very good advisors,” and added, “they are very cohesive and have vast experiences.” Clients agreed that they get good value from the Firm; “It’s outstanding client service and worth every penny. Billing has been very detailed and understandable.Continue Reading McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2018

Wrapping Up April – and Looking Forward to May

Top April Posts You May Have Missed

President Trump Announces Intent to Nominate Emin Toro to Tax Court

IRS Releases Practice Unit on Statutes of Limitation

National Taxpayer Advocate Reminds Congress of IRS Deficiencies

Tax Controversy Activities This Week

May 1, 2018: Elizabeth Erickson is on “Exchange of Information – The New Landscape” at the TEI Audits and Appeals Seminar in New Orleans, LA.

May 3, 2018: Andrew Roberson is presenting “Preventing Disputes 2: Taxpayer Rights in the Administrative Phase” at the International Conference on Taxpayer Rights in Amsterdam, Netherlands.

Upcoming Tax Controversy Activities in May

Our lawyers will present on the following key tax topics during the month of May. We hope to see you.

May 7, 2018: Kristen Hazel and Michael Louis will present “Navigating Tax Reform: BEAT and FDII” at TEI-Houston Chapter 2018 Tax School in Houston, TX.

May 10, 2018: Robin Greenhouse and Kevin Spencer are going to speak about tax controversy and privilege at the International Fiscal Association’s New York/Connecticut Region meeting in Old Greenwich, CT.

May 11, 2018: Elizabeth Erickson will discuss “Section 162(q) – No Longer Silent” at the ABA Section of Taxation Meeting in Washington, DC.

May 11, 2018:  Stephen Kranz will present “Handling Tax Controversy to Win” and “The Digital Tax Tsunami:  What You Need to Know to Help Your Clients” at Avalara’s CRUSH DC 2018 in Washington, DC.

May 21-22, 2018: Thomas Jones is presenting “Impact of the Change in Corporate Tax Rates & Other Tax Developments” at the Texas Captive Insurance Association 5th Annual Conference in Houston, TX.

Wrapping Up March – and Looking Forward to April

Top March Posts You May Have Missed

White House Intends to Nominate Michael J. Desmond to High-Level Roles in the IRS and the Department of Treasury

The IRS May Be Coming for Your Bitcoins

Tax Court Judicial Conference This Week in Chicago

Upcoming Tax Controversy Activities in April

Our lawyers will present on key tax topics during the month of April. We hope to see you soon.

April 24, 2018: Todd Welty, Kristen Hazel, Elizabeth Erickson, John Lutz and Andrew Roberson will present “Taking Reasonable Positions and Retroactive Regulations” at McDermott’s Inaugural Tax Symposium in our Chicago office. The panel will address Gottesman, the ability of IRS to issue retroactive regulations, IRS authority issues, and impacts on return positions.

Led by our senior practitioners, our 2018 Symposium is a must-attend event for senior tax and employee benefits leaders seeking to optimize the opportunities and navigate the risks brought about by tax reform legislation.

April 30, 2018: Thomas Jones will present “Captive Insurance Tax Reform Update” at the Captive Insurance Council of the District of Columbia in Washington, DC. Captive Insurance has undergone a number of changes since the tax reform movement and our partner Tom Jones will cover the new regulations that your organization should be aware of.

The Tax Court’s 2018 Judicial Conference starts tomorrow morning on the campus of Northwestern University’s Pritzker School of Law. For prior coverage, see here. The many panels taking place tomorrow and Wednesday include:

  • Mediation in the Tax Court
  • Discovery and Stipulations Process
  • Litigating Individual Cases
  • Large Case Litigation
  • Whistleblower Jurisdiction
  • A Trip Through the Tax Court’s Exotic Jurisdictions
  • Ethical Issues in Representing Clients
  • The Future of Tax Court Practice and Litigation

I will be participating on the Discovery and Stipulations Process panel along with Tax Court Judges Kathleen Kerrigan and Joseph Goeke, Peter Reilley (Special Counsel IRS), and Jenny Johnson Ware (Johnson Moore).

Wrapping Up December – and Looking Forward to January

You can view all of the topics we discussed over the last month, and take a look at the upcoming tax controversy events where our lawyers will be speaking in January.

Upcoming Tax Controversy Activities in January:

January 23, 2018: Diann Smith will be presenting “State Transfer Pricing Audits: Effective Strategies to Minimize Your Risk” at the 27th Annual Ohio Tax Conference in Columbus, Ohio.

January 24, 2018:  Stephen Kranz is presenting “Handling State Tax Controversies to Win!!” at the 27th Annual Ohio Tax Conference in Columbus, Ohio, solving tax problems holistically to achieve success, understanding the offensive and defensive tools available and the avenues for relief when interacting with the government, planning and building the team to effectively work all avenues the government offers, tools available including FOIA, policy solutions, and litigation, with Jeff McGhehey, Senior Manager, Indirect Tax, The Home Depot.

McDermott Will & Emery recently published Issue 3, 2017 of International News, which covers a range of legal developments of interest to those operating internationally.

This issue focuses on the upcoming Brexit from the European Union and the changes in the US Administration; both subjects which have dominated headlines over the past year. This issue explores ways in which prepared investors and businesses can continue to function effectively during this period of uncertainty and change.

Read full issue.

Wrapping Up November – and Looking Forward to December

Please view all of the topics we discussed over the last month, and take a look at the upcoming tax controversy events where our lawyers will be speaking in December.

Upcoming Tax Controversy Activities in December:

December 14, 2017: Catherine Battin, Britt Haxton, Kristen Hazel, Mary Kay Martire, Jane May, Sandra McGill and Judith Wethall will be hosting the Tax in the City® – A Year in Review event, which will focus on the state and local impact, as well as the federal and international aspects of tax reform.

December 14, 2017: Thomas Jones will be presenting the webinar, “Understand how the new Tax Reform bill will affect the status of captive insurers and hear the latest 2017 tax developments” for the Vermont Captive Insurance Association.

Following up on our pro bono post last week, we wanted to highlight a recent article in the ABA Tax Times regarding tax impacts of natural disasters. The article discusses resources available to taxpayers and volunteers dealing with the after-effects of a natural disaster and emphasizes the need for tax assistance long-after the natural disaster occurs. If you have a few moments and/or are interested in ways you might be able to help, please take a quick look.

As we have written about before, there is a substantial need for pro bono assistance to low-income taxpayers throughout the country. A sample of some of the tremendous results obtained by pro bono volunteers can be found here. As strong proponents of pro bono, both in tax law and other areas of the law, we have seen firsthand the difference that a few hours of your time can make in the life of an individual that cannot otherwise afford to pay for legal representation.

The American Bar Association (ABA) Section of Taxation annually selects one individual or law firm as the recipient of the Janet Spragens Pro Bono Award. The award was established in 2012 to recognize outstanding and sustained achievements in pro bono activities in tax law. The ABA is seeking nominations for the 2018 recipient, which must be submitted by December 8, 2017. More information about the criteria for selection and a list of prior recipients can be found here. If you know of an individual or a law firm that would be a worthy nominee, please do not hesitate to submit your nomination to the ABA Section of Taxation. We note that all nominations are maintained in strict confidence by the Pro Bono Award Committee.