09.22.2020

The IRS's Large Business and International Division (LB&I) recently requested comments from large corporate taxpayers that rely on Revenue Procedure 94-69 to disclose potential tax adjustments

Tax Alert

07.27.2012

In this article, Jim Gadwood describes the Internal Revenue Service's (IRS's) increased scrutiny of inbound financing leading to attempts to recharacterize related-party debt as equity.