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U.S. Tax Review: APA Update; Perrigo; Rawat, Kyocera, Mann; Cryptocurrency; Net Investment Income Tax - Transfer Pricing

The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation. ....

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Administrative Procedure Act Violations by IRS Notices

Taxpayers who are not parties to an action voiding an IRS Notice published without notice and comment should consider the risk of the IRS may nonetheless treat the Notice as valid as to nonparties. Federal courts held the IRS notices violate the Administrative Procedure Act. ....

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An IRS Notice That a Court Vacates and Sets Aside May Still Be Enforceable Against Nonparties | Miller Canfield

Taxpayers who are not parties to an action voiding an IRS Notice published without notice and comment should carefully consider the risk that the IRS may nonetheless treat the Notice as. ....

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IRS Regulations to Identify Syndicated Conservation Transactions

IRS proposed regulations to identify syndicated conservation easement transactions as listed transactions. U.S. Tax Court held that Notice 2017-10, designated syndicated conservation easement transactions as listed transactions, was invalid and issued in violation of the APA. ....

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The IRS is Not Backing Down: Proposed Regulations Issued Regarding Abusive Tax Shelters Including Certain Syndicated Conservation Easement Transactions | Polsinelli

Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement. ....

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