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Virtual IRS Appeals – A New Frontier?

The Internal Revenue Service Office of Appeals (IRS Appeals) recently announced that it will offer a new virtual “face-to-face” option in the form of web-based communication to taxpayers and representatives to resolve tax disputes. IRS Office of Appeals Pilots Virtual Service, IRS (July 24, 2017. This announcement comes on the heels of other changes at IRS Appeals that curtail the ability of taxpayers to have face-to-face hearings with IRS Appeals. The IRS cites the need for the new service because of IRS Appeals’ large (and growing) case load—more than 100,000 cases each year! For some our prior coverage on recent changes at IRS Appeals, see here, here, here and here. Practice Point: In the wake of an ever-shrinking budget, resources and staff, the IRS really has no choice but to try new and arguably more efficient methods to move cases along. The backlog of cases at IRS Appeals is staggering, and our clients are experiencing long wait times until a case is...

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McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2017

Chambers USA, which releases an annual listing of rankings of law firms and attorneys in various practice areas, has released its 2017 edition. We are honored that Chambers USA has recognized McDermott’s tax practice and several of its attorneys 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. In the nationwide rankings for Tax Controversy, we maintained our Band 2 ranking. In the state rankings for Tax, we are ranked in Band 1 for Illinois, Band 2 for Washington, DC and Band 3 for Texas. 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 gave us “10 out of 10 for client service,” and added: “They are great at investing in and building a long-term relationship.”  Particularly noted is the value for...

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Preparing for a Tsunami of International Tax Disputes

Recently, we published a Special Report in Tax Notes International, “Preparing for a Tsunami of International Tax Disputes.”  The article can be accessed here.  While there is near-universal agreement that the number of tax disputes is going to increase, existing international tax dispute resolution processes remain in serious need of improvement. A global consensus must be reached on a process for resolving worldwide tax disputes that appeals to all stakeholders. This article focuses on recent attempts by the Organisation for Economic Development (OECD), United Nations (UN) and international tax community to achieve such a consensus. In short, the predictability of tax base results is a serious concern for countries and multi-national enterprises alike.  The only realistic solution is to design a dependable and independent treaty-based dispute resolution process that accommodates the needs of all stakeholders. A foundation for this process has been provided...

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