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OECD Delays Pillar One of International Tax Reform to Mid-2023

The Organisation for Economic Co-operations and Development (OECD) is delaying the implementation of Pillar One of the landmark agreement on international tax reform. A new Progress Report on Pillar One, which includes “a comprehensive draft of the technical model rules to implement a new taxing right that will allow market jurisdictions to tax profits from […]

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GAO: IRS Faced Multiple Challenges During 2021 Tax Filing Season, GAO Report: Tax Filing—2021 Performance Underscores Need for IRS to Address Persistent Challenges

The Government Accountability Office (GAO) has issued a report on IRS’ performance during the 2021 tax filing season. The report assessed IRS’ performance during the 2021 filing season on: (1) processing individual and business income tax returns; and (2) providing customer service to taxpayers. GAO analyzed IRS documents and data on filing season performance, refund […]

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Filing Deadline for Petition to Review CDP Determination Nonjurisdictional, Eligible for Equitable Tolling

The Supreme Court reversed and remanded a Court of Appeals decision and held that Code Sec. 6330(d)(1)’s 30-day time limit to file a petition for review of a collection due process (CDP) determination is an ordinary, nonjurisdictional deadline subject to equitable tolling in appropriate cases. The taxpayer had requested and received a CDP hearing before the […]

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Eligibility Requirements Waived for Individuals in Certain Countries Claiming Foreign Earned Income Exclusion

The IRS has provided a waiver for any individual who failed to meet the foreign earned income or deduction eligibility requirements of Code Sec. 911(d)(1) because adverse conditions in a foreign country precluded the individual from meeting the requirements for the 2021 tax year. Qualified individuals may exempt from taxation their foreign earned income and housing cost […]

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Government Employees Who Receive Returns or Return Information Subject to Disclosure Restrictions

The IRS has issued a guidance stating that government employees who receive returns or return information pursuant to disclosures under Code Sect. 6103(c), are subject to the disclosure restrictions, like all designees who receive returns or return information pursuant to taxpayer consent. Further, government employees who receive returns or return information pursuant to disclosures under Code Sec. […]

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