KPMG Practitioners Discuss IRS Audit Dispute Resolution Strategies, New IRS Procedures

Members of KPMG’s tax controversy services practice, in a May 5 webcast, provided resolution strategies that taxpayers need to consider when the taxpayers and the Internal Revenue Service…

Economic Substance Changes Would Have Biggest Impact on Firms in Three Circuits

Taxpayers operating in the regions covered by the Courts of Appeal of the Second, Fourth, and Eighth Circuits will be most affected by the health care law’s changes to the way the economic substance doctrine is applied to…

ANALYSIS: The Wells Fargo Case and Economic Substance: Revisiting the Blueprint for Taxpayer Success

Nancy Bowen of Fulbright & Jaworski LLP follows up on an earlier Viewpoint article she co-authored that analyzed two recent taxpayer victories on economic substance: Consolidated Edison Co. v. United States and…

ANALYSIS: State Taxes in 2009: The Year in Review

KPMG’s review of state taxation in 2008 began with the quote, “It was the best of times, it was the worst of times …”; in contrast, 2009 generally was the worst of times—from start to finish…

ANALYSIS: The Tax Court’s Duty to Apply the Properly Applicable Law

Normally the Tax Court, like other trial courts, lets the parties try their cases, and does not further complicate its…

Transfer Pricing Cases Converge as Tax Court Orders VERITAS Inc. to File Post-Xilinx Report

After finding for the taxpayer in VERITAS Software Corp., U.S. Tax Court Judge Maurice Foley Jan. 28 ordered the company and the Internal Revenue Service to…