Tax Law News and Insights

It is the duty of any tribunal to consider the evidence presented before it. A recent Ohio Board of Tax Appeals (BTA) decision reminds us that the same duty applies to the Ohio Tax Commissioner (the Commissioner) during the audit and assessment process. On March 21, 2022, the Ohio BTA...

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In a recent Legal Update1, we discussed the emerging intersection between Tax and ESG and highlighted the various external stakeholders pressuring for greater visibility into the global tax positions of multinational companies (MNEs). One increasingly vocal stakeholder group is activist shareholders. Recently, a group of institutional investors of a Fortune...

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The prospect of forcing the IRS to pay legal fees can be an enticing one. And the qualified offer provides a strategic weapon to do just that. A taxpayer who makes a qualified offer to the IRS and later prevails in court can recover legal fees and other costs from the IRS. How's that...

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