Insights
Professional
Practice
Industry
Region
Trending Topics
Location
Type
Sort by:
Client Alerts 4 results
Client Alert | 6 min read | 10.24.25
Will Jarkesy Stop the IRS from Asserting Penalties Against Taxpayers?
In 2024, the U.S. Supreme Court determined that the civil penalties issued by the SEC against individuals for committing securities fraud were unconstitutional because they were levied without a jury trial.[1]
Client Alert | 3 min read | 10.07.25
Blocking the Blocked Income Rules? Loper Bright’s influence over the Eighth Circuit’s 3M decision.
On October 1, 2025, the Eighth Circuit decided 3M Co. v. Commissioner in the taxpayer’s favor, based on its application of Loper Bright. The question presented in the case was whether the IRS had the authority to reallocate royalty income to a U.S. parent company that its foreign subsidiary was prohibited from paying under foreign law. The court held that the best interpretation of the governing statute did not permit the IRS’s reallocation.
Client Alert | 3 min read | 08.13.25
Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes
On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”
