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AI Tools for Tax Attorneys
AI tools that help tax attorneys research IRS rulings, find tax court precedents, analyze SEC filings for tax disclosures, and monitor regulatory changes.
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Cases Found
34 Tax Court and circuit decisions involving §482 disputes
Top Case
Coca-Cola Co. v. Comm'r (2023) — $3.4B IRS adjustment upheld on royalty pricing
IRS Win Rate
71% — IRS prevailing on transfer pricing adjustments in this period
Penalty Exposure
40% transactional penalty applied in 18 of 34 cases
Trending Issue
Digital IP licensing arrangements drew most new adjustments 2022–2024
Tax court and IRS case law research
Search Tax Court memoranda, federal circuit opinions, and SCOTUS tax decisions for precedents. Find how courts have ruled on specific statutory interpretations, penalties, and IRS procedural challenges.
Find Tax Court and circuit court decisions from 2018–2024 involving the IRS disallowing conservation easement deductions under IRC 170(h). What penalties were upheld?
Found 28 relevant decisions. Pattern: Syndicated conservation easement transactions facing near-universal disallowance + 40% gross valuation misstatement penalty. Key case: Plateau Holdings v. Comm'r (11th Cir. 2022) — 40% penalty upheld, charitable deduction denied in full. Tax Court sustaining IRS positions at 94% rate in this category. 6 cases pending Supreme Court cert.
ToolRouter search_cases
Cases Found
28 decisions — syndicated conservation easement transactions
Disallowance Rate
94% of Tax Court cases: IRS position sustained in full
Key Precedent
Plateau Holdings v. Comm'r (11th Cir. 2022) — 40% penalty upheld, deduction denied
Gross Valuation Penalty
40% penalty upheld in near-universal pattern across decisions
SCOTUS Petitions
6 cases pending cert — no circuit split yet, cert unlikely
IRS regulatory and guidance research
Look up Revenue Rulings, PLRs, Technical Advice Memoranda, and recently-issued proposed regulations. Know the IRS's position on novel transactions before your client takes a reporting position.
What is the current IRS guidance on the tax treatment of cryptocurrency staking rewards? Is there a Revenue Ruling or proposed regulation addressing when income is recognized?
IRS Rev. Rul. 2023-14 (July 2023): Staking rewards are gross income in the year received, valued at fair market value at time of receipt. Jarrett v. United States (M.D. Tenn. 2022) refund case — IRS later reversed its refund position consistent with Rev. Rul. 2023-14. Proposed regulations on digital asset broker reporting (Reg-122793-19) effective Jan 2025 — add Form 1099-DA reporting.
ToolRouter research
Rev. Rul. 2023-14
Staking rewards are gross income in the year received, valued at FMV at receipt
Jarrett v. United States
M.D. Tenn. 2022 refund case — IRS reversed refund position consistent with Rev. Rul.
Reg-122793-19
Digital asset broker reporting regs — Form 1099-DA required effective Jan 2025
Open Issues
Staking-as-services (validator pools) vs. direct staking income recognition timing
Tax rate and bracket reference
Instantly access current federal tax brackets, capital gains rates, estate and gift tax thresholds, NIIT rates, and SALT deduction limits. Run quick tax estimates for structuring discussions without pulling out old returns.
My client is selling a business for $8M in 2025. What's the federal tax on the gain if it qualifies as long-term capital gain? He has $1.2M in other income. Include NIIT.
2025 LTCG rate at $9.2M total income: 20%. NIIT: 3.8% (net investment income over $200K threshold). Combined federal rate on LTCG: 23.8%. Estimated federal tax on $8M gain: ~$1.904M. State tax varies — if in California: add 13.3% = total effective rate ~37.1%. Structuring as installment sale could reduce net present value of tax.
ToolRouter get_brackets
Tax typeRateAmount on $8m gain
Long-Term Capital Gains20%$1,600,000
Net Investment Income Tax3.8%$304,000
Combined Federal Rate23.8%$1,904,000
California Add-on13.3%+$1,064,000
Total effective rate ~37.1% if California resident · installment sale may reduce NPV
Corporate tax disclosure review
Review SEC filings to analyze how public companies disclose uncertain tax positions (ASC 740), IRS examination results, and deferred tax liabilities. Use this for M&A tax diligence or to benchmark client disclosures.
In Apple's last 3 annual reports, what was the total amount of unrecognized tax benefits (UTBs) and were there any material IRS examination disclosures?
2022: UTBs $16.8B. Active IRS examination of years 2014–2018. 2023: UTBs $18.1B. IRS expanded exam to 2019–2021. 2024: UTBs $19.7B. EU State Aid case (Ireland) — €13B potentially payable pending appeals. Note: Apple's effective tax rate vs. statutory rate gap of 7.2 points driven primarily by foreign earnings structure.
ToolRouter search_filings
YearUtb balanceIrs exam period
2022$16.8B2014–2018
2023$18.1B2019–2021
2024$19.7B2020–2022
Effective rate gap vs. statutory: 7.2 pts — driven by foreign earnings structure
International tax and compliance research
Research OECD Pillar Two global minimum tax implementation, FATCA compliance requirements, CFC rules, and treaty positions for cross-border transactions. Stay current on rapidly evolving international tax law.
Which countries have implemented OECD Pillar Two (15% global minimum tax) as of 2025, and what is the status in the US? Does my client's Cayman Islands subsidiary face IIR or UTPR exposure?
Pillar Two in force: EU (all member states), UK, Japan, Canada, Australia, South Korea, Switzerland — 40+ jurisdictions as of 2025. US: GLOBE rules not enacted (CAMT is not equivalent). Your Cayman subsidiary: no local QMT. IIR exposure: Yes — if any parent jurisdiction applies IIR (EU, UK, Canada). UTPR: May apply in parent's jurisdiction against undertaxed profits.
ToolRouter research
Jurisdictions in Force
EU (all member states), UK, Japan, Canada, Australia, South Korea, Switzerland — 40+ total
US Status
GLOBE rules not enacted — CAMT (15% book minimum tax) is not equivalent
Cayman Subsidiary IIR Exposure
Yes — if any parent jurisdiction (EU, UK, Canada) applies IIR, top-up tax triggered
UTPR Exposure
May apply in parent's jurisdiction against undertaxed Cayman profits
Ready-to-use prompts
Transfer pricing case search
Find US Tax Court and federal circuit decisions from 2017–2024 involving IRS challenges to intercompany royalty payments from US subsidiaries to foreign IP holding companies. Include the court's analysis and outcome.
SALT deduction research
What is the current federal SALT deduction cap under the TCJA, which states have enacted SALT workaround PTETs, and what is the current IRS guidance on PTET deductibility at the entity level?
Estate tax calculation
What is the 2025 federal estate tax exemption amount, the marginal rate above the exemption, and the annual gift tax exclusion? Also include the GST tax exemption and rate.
IRS penalty case research
Find Tax Court cases from 2020–2024 where the court abated or reduced accuracy-related penalties under IRC 6662 because the taxpayer relied on competent professional advice. What constitutes "reasonable cause" in these cases?
Crypto tax guidance
Research all IRS guidance, Revenue Rulings, and Notice publications on cryptocurrency tax treatment from 2014 to present. Include the treatment of forks, airdrops, staking, and NFT sales.
Corporate tax rate reference
Summarize the current US corporate tax rate, GILTI inclusion rate for 2025, BEAT rate, and FDII deduction percentage. Also show how the OECD Pillar Two 15% minimum rate interacts with GILTI.
Uncertain tax position review
Find all 10-K filings where Alphabet disclosed increases in unrecognized tax benefits exceeding $500M in a single year. What were the reasons disclosed and the IRS examination years involved?
Partnership audit case research
Research the BBA centralized partnership audit rules enacted in 2015. Find Tax Court cases from 2020–2024 interpreting partnership-level adjustments and the push-out election.
Tools to power your best work
Deep ResearchAI research reports with citations
PDFRead, analyze & merge PDFs
Tax ReferenceUS tax brackets, rates & limits
Financial CalculatorDCF, bonds, options & portfolios
Compliance ScreeningAML, sanctions, PEP & due diligence investigations
Legal ResearchCase law, statutes, regulations & legislation worldwide
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Business sale tax structuring analysis
Before advising on a business sale structure, research applicable rates, precedents for similar deals, and IRS examination risks.
1
Tax ReferencePull current capital gains rates, NIIT, and ordinary income brackets for all scenarios
2
Legal ResearchFind precedents for the proposed transaction structure (asset sale, stock sale, 338(h)(10))
International tax due diligence for cross-border acquisition
Assess the target company's international tax exposure and structure before a cross-border acquisition.
Frequently Asked Questions
Does the case law tool include Tax Court memoranda and summary opinions?
Legal Research indexes published US Tax Court decisions, Tax Court Memoranda (T.C. Memo), and Summary Opinions (T.C. Summary). Federal Circuit, D.C. Circuit, and other circuit court tax decisions are also included, along with SCOTUS tax opinions.
Can I find IRS Revenue Rulings and PLRs with these tools?
Deep Research can locate Revenue Rulings, Revenue Procedures, Notices, PLRs (which are publicly released with identifying information redacted), and Technical Advice Memoranda through publicly available IRS publications. For current PLR status, cross-reference with the IRS FOIA portal.
How current is the tax reference data?
Tax Reference is updated annually for each tax year and reflects IRS inflation adjustments as published. For mid-year legislative changes (like those enacted by reconciliation bills), verify against the latest IRS announcements and the relevant IRC sections.
Can these tools help with state and local tax research?
Deep Research covers major state tax provisions and case law. Tax Reference includes federal data primarily, with selected state references. For SALT-specific research across all 50 states, use Deep Research and specify the state jurisdiction in your query.
Can I use the SEC filings tool to benchmark client tax disclosures against industry peers?
Yes. SEC Filings lets you compare effective tax rate disclosures, UTB balances, deferred tax asset valuation allowances, and IRS examination disclosures across peer companies in the same industry. This is useful for advising clients on disclosure adequacy and audit risk positioning.
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