JD Supra

IRS Issues Interim Guidance Eliminating the Acknowledgement of Facts and Expanding Access To Dispute Resolution Programs

The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. 1 Specifically, the ...
JD Supra

IRS Tax Controversy Guide: Navigating the Process from Notice to Resolution

Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax ...
JD Supra

New IRS Mediation Pilot: A Better Path to Resolution

Starting October 1, 2025, the IRS launched a two-year pilot program that could save taxpayers significant time and money in resolving tax disputes. The enhanced Post Appeals Mediation (PAM) program ...
JD Supra

IRS Procedural Reforms Aim To Allow Early Resolution of Controversies With Businesses

The IRS has announced a series of procedural changes this year intended to streamline the audit and issue resolution process for large and international businesses. The changes will make it easier for ...
JD Supra

A Depleted IRS May Turn to Expedited Processes to Work Off Dispute Backlog

By any measure, 2025 was a tumultuous year for the Internal Revenue Service (IRS), leaving a slimmed-down organization ...