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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November 2017

  • District Court concludes that taxpayer’s refund suit, relating to the carryback of a deduction for foreign taxes, was untimely
  • IRS issues chief counsel advice that the small partnership exception to filing a return is not automatic
  • Tax Court concludes disclosures in successor entity’s return was sufficient to begin the assessment statute of limitations
  • TAS comments that the evolving IRS policy on Form 1042-S refund claims continues to present challenges to nonresident aliens
November 2017


September 2017
Federal Circuit Affirms FPAA Tolled Statute for Partnership when Losses were “Attributable To” Another Partnership

July 2017
Tax Court Holds that Certain Tax Return Information May Be Disclosed to an Employer Asserting a Defense to Withholding Tax

May 2017
US Tax Court sides with Amazon in intangibles transfer case

March 2017
The Sixth Circuit Court of Appeals Limits IRS’ Use of Substance over Form Doctrine

January 2017
The Federal Circuit Court of Appeals Holds Tax Shelter Penalties for Failure to Register Are Not Divisible

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