Practitioner Insights

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Bloomberg Tax Journals

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US Must Lead Global AI-Driven Tax Transparency Standards Now

The US faces a critical choice between leading or following global digital tax transparency standards.

Why Company Readiness Beats Reaction When Navigating Tax Policy

The key areas of focus for tax departments in 2026 are discussed.

When Courts Say No: 3M and the Future of Treasury Regulations

The Eighth Circuit’s decision in 3M demonstrates a shift towards textual statutory interpretation, restricting IRS authority to reallocate income across international boundaries.

Tax Developments

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IRS PLR: Qualified Opportunity Fund Self-Certification Election Filing Treated as Timely (IRC §1400Z)

The IRS has published a private letter ruling on I.R.C. §1400Z and Treas. Reg. §§301.9100 and 1.1400Z2, allowing the taxpayer’s Form 8996 election for self-certification as a qualified opportunity fund ...

Case: U.S. District Court Dismisses Taxpayer’s Claims Against IRS Due to Lack of Jurisdiction, Procedural Failures

The U.S. District Court held that it lacked subject matter jurisdiction over the taxpayer’s claims against the IRS and an IRS agent for trespass and interference with business relationships related ...

Case: U.S. District Court Upholds IRS’s Right to Foreclose on Property for Unpaid Taxes, Invalidates Spouse’s Trust Transfer

The U.S. District Court held that the IRS was entitled to reduce federal tax assessments against the taxpayer to judgment and foreclose federal tax liens on a residential property. The ...

Companies Face Tariff-Induced Transfer Pricing Audit Risks

Enrolled Agents Anticipate IRS Chaos for Next Tax Filing Season

Congressional Deadline on Shutdown Deal Adds to IRS Challenges

IP Poses Risks, Opportunities for Companies' Tariff Planning

IRS Shakeup: How Is the US Tax Agency Adapting to Trump's Vision?

Since President Donald Trump took office, the IRS has faced transformative changes, including a substantial reduction in its workforce and the appointment of seven different commissioners or acting commissioners.

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