Managing tax risk is one of the greatest challenges for tax departments around the world (creating the opportunities to build relationships with revenue services), starting with the verification audit through to the resolution of tax controversies. A recent survey supports this contention. Key...

The ability of the Internal Revenue Service (IRS) to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice (“Justice”) stating that the President and...

Twenty-five of the nation's leading tax academics, practitioners, journalists, and public intellectuals gathered in Malibu, California on the Friday before President Obama's second inauguration to plead for tax reform. The papers published in this issue of the Pepperdine Law Review provide very...

This article asks whether tax planning advice can ever be effectively regulated by the IRS. The article first explores whether tax advice differs in kind from other forms of legal advice. Secondly, it looks at the clear regulatory distinction between the treatment of return preparation advice...

Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International's corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages,...

Internal Revenue Code section 7122 provides that “the Secretary may compromise any civil or criminal case arising under the internal revenue laws . . . .” This simple language supplies a statutory hook for the Internal Revenue Service's (IRS's) “Offer in Compromise” (OIC) program, one of...