Key Takeaways
- OECD Digital Tax
- Frank Bisignano’s Future
- IRS Modernization Plan
- IRS Reform Bill
- State Apportionment
- In the Courts
- Tea for Two Tuesday
OECD Digital Tax
OECD Digital Tax Talk Prospects Overshadowed by ‘US Fatigue’ – Lauren Vella and Saim Saeed, Bloomberg ($):
The US has called for negotiators to start from zero on a decade-long project aimed at stopping digital taxes on its tech companies like Meta Platforms Inc., Alphabet Inc., and Amazon.com Inc. The project aimed to reallocate a fraction of the profits from some of the largest companies in the world to the countries where sales are made.
House Members to Renew Anti-Digital Services Tax Call – Chris Cioffi, Bloomberg ($):
Lawmakers from both parties have slammed these levies, arguing they discriminate against American tech giants. But foreign countries say that these companies need to pay their “fair share” because they make money off their constituents and user data—even without a large physical presence.
Frank Bisignano’s Future
IRS CEO to Stay in Role for Foreseeable Future, Official Says – Erin Slowey, Bloomberg ($):
Assistant Secretary for Tax Policy Ken Kies told the Tax Executives Institute conference. “Frank’s not going anywhere.”
IRS Modernization Plan
IRS Found to Lack Plan to Shrink Taxpayer Correspondence Backlog – Chris Cioffi, Bloomberg ($):
An agency backlog of taxpayer correspondence remained above pre-pandemic levels at the end of filing season and fiscal year 2025, as the IRS sought to balance demands of answering taxpayer calls and correspondence, according to a U.S. Government Accountability Office report.
IRS Needs Plan To Tackle Staffing Cuts, Backlogs, GAO Says – Stephen K. Cooper, Law360 ($):
Balancing the demands of phone service and correspondence is a continued challenge for the Internal Revenue Service, which lost more than 17,000 employees in 2025 via deferred resignation and early retirement programs, the GAO said, noting that roughly one-third of those workers processed returns and provided customer service.
IRS Modernization Plan Found Lacking Oversight – Benjamin Valdez, Tax Notes ($):
The Government Accountability Office, in a report released March 16, said the IRS lacks a team to oversee the implementation of several modernization initiatives and an updated workforce plan following the exodus of thousands of staff.
IRS Reform Bill
Wyden Plugs IRS Reform Bill Following Report on Return Preparers – Katie Lobosco, Tax Notes ($):
The report, released March 16 by the Center for Taxpayer Rights, says the IRS collects less than 20 percent of the preparer penalties it assesses. The study is based on “mystery shopping” visits the group conducted during the 2025 filing season, as well as its 2024 nationwide survey of low-income taxpayers.
Report: 2025 Filing Season Mystery Shopping Visits
State Apportionment
New Int'l Tax Rules May Spur State Apportionment Arguments – Maria Koklanaris, Law 360 ($):
The professionals spoke about "net CFC tested income," which was new in H.R. 1, the tax bill signed last year by President Donald Trump. The new income, or NCTI, replaced global intangible low-taxed income, or GILTI. With that change came some tax benefits for corporations on the federal level but an increase, for states that conform, of international income in the state tax base. That creates more distortion, the panelists said, opening an additional argument for alternative apportionment. They spoke on a panel in New Orleans hosted by the American Bar Association's tax section and the Institute for Professionals in Taxation.
In the Courts
Judge Rejects Seventh Amendment Challenge to FBAR Judgment – Amanda Athanasiou, Tax Notes ($). “A U.S. magistrate judge recommended that a district court deny Isac Schwarzbaum’s latest efforts to avoid a roughly $19 million judgment against him, saying that recent cases on taxpayers’ Seventh Amendment rights don't help him.”
Tax Court Tosses Biotech Co.'s Case Over Corporate Status – Kat Lucero, Law 360 ($). “A California biotechnology company's challenge to an IRS lien cannot stand, the U.S. Tax Court found, because the company's corporate status was not restored within the statute of limitations to file suit.”
Biotech’s Tax Court Petition Fails Due to Suspended Status – James Matheson, Bloomberg ($). “A California company can’t challenge an IRS collection action because it lacked the legal capacity to file a petition while its corporate status was suspended under state law, the US Tax Court held Monday.”
What Day is it?
Obviously, it’s Saint Patrick’s Day. But, also exciting, it’s Tea for Two Tuesday! Grab someone you love, or like even a little, and celebrate!
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