IRS Insights


IRS Insights

A closer look.

IRS Insights, published by the Deloitte Tax LLP Tax Controversy Services group, provides a compact, reader-friendly perspective on the latest practices and procedures coming out of the Internal Revenue Service (IRS), as well as the potential impact of changes on taxpayers.

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Recent editions appear below; for older issues, please email a request to

January 2019

  • US Court of Appeals rules that taxpayer and its subsidiary foreign sales corporation are not the same taxpayer – Interest netting rules of Section 6621(d)
  • District Court enforces IRS summons of taxpayer internal memoranda cited in a valuation report prepared by a law firm
  • Khafra v. IRS: What constitutes an extension of time to file for purposes of the lookback period under Section 6511(b)(2)(A)?
  • GAO Report recommends reforms to improve the case resolution timeliness of the IRS Appeals Office
January 2019


November 2018
Informal Refund Claims – Birger Engineering

September 2018
IRS Announces Eleven New Large Business and International Compliance Campaigns

July 2018
District Court Determines IRS Exceeded Regulatory Limit on FBAR Penalties

May 2018
Recent Update to the Partnership Audit Rules: Technical Corrections Act of 2018

March 2018
IRS LB&I Division Issues Transfer Pricing Guidance

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