During the January 2019 ABA Tax Section 2019 Midyear Tax Meeting, Kat Gregor, tax partner and co-founder of the tax controversy group, discussed the new EU mandatory disclosure rules (known as DAC6 related to aggressive tax positions) and the ethical obligations of U.S. attorneys to adhere to these rules. Kat noted that “the EU rules are, on the one hand, trying to be more precise as to what they’re interested in catching, rather than in the U.S., where they say any transaction over a certain dollar value has to get reported. But on the flip side, it’s going to be really difficult for people to make the judgment call on whether or not something falls in.”

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