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
Miller & Chevalier lawyer Jim Gadwood and co-author Paul Morton, former Tax Director for the U.K.
In this chapter for Major Tax Planning
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
In this article, Jim Gadwood analyzes the Appeals Judicial Approach and Culture (AJAC) Project and
In this article, Jim Gadwood provides an overview of the Internal Revenue Service's (IRS's) Large Busine
In this article, Jim Gadwood discusses the implications of miscalculated net operatin
This article, co-authored by Jim Gadwood, discusses the U.S.
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.
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