In May 2016, we published an Alert about UK proposals to introduce new strict liability corporate criminal offences aimed at preventing the facilitation of tax evasion. Andy Howard, Tax partner in the Ropes & Gray London office, also recently recorded a short video on the topic for our Trending Legal Topics series. The UK has recently confirmed that the relevant legislation will come into effect on September 30, 2017. In this Alert we recap on the key aspects of the new offences, and the steps that businesses should take in order to protect themselves ahead of commencement.

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“Understanding the opposition is the single biggest asset that a company can have going into any tax enforcement proceeding,” states Ropes & Gray’s Kat Gregor in a forum on resolving tax disputes published in Corporate Disputes Magazine. Read the entire article, which features more tips for handling tax disputes and insights about the current enforcement climate, here.

On May 22, 2017, Ropes & Gray hosted a reception featuring Special Trial Judge Peter J. Panuthos of the U.S. Tax Court to re-launch the Boston Chapter of the FBA Tax Section. Read more about the event here, or if you’re interested in participating in or helping to organize a future event, please reach out directly to Gabby or Ryan at gabrielle.hirz@ropesgray.com or ryan.montgomery@ropesgray.com.

In February 2017, Ropes & Gray LLP published an article discussing recent reductions in the IRS budget and the resulting decline in enforcement, which has led to a gap of approximately $450 billion per year between the amount of tax that should be paid by U.S. taxpayers and the amount that is actually paid. The article also addressed possible changes to IRS funding in the new presidential administration.

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In January 2017, the IRS announced the rollout of thirteen compliance campaigns to be undertaken by its Large Business and International Division (“LB&I”). The campaigns are part of a broader effort by the IRS to reorient LB&I to focus on high-risk issues in order to more efficiently address non-compliance in an era of smaller IRS budgets and greater IRS responsibilities. The campaigns cover subjects including repatriation of overseas funds by U.S. taxpayers, related-party transactions, and TEFRA partnership examinations.

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In February 2017, Ropes & Gray LLP issued a client alert discussing material aspects of the proposed regulations released by the Department of Treasury implementing the partnership audit provisions of the Bipartisan Budget Act of 2015. The Bipartisan Budget Act rules created a new regime for auditing partnerships, repealing the Tax Equity and Fiscal Responsibility Act rules that have been in place since 1982. The proposed regulations provide much-needed guidance on a number of issues. Continue reading.

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