Photo of Ellen Gilley

In a recent Law360 article, members of the international arbitration group, Kat Gregor (also tax partner and tax controversy group co-founder) Nick Berg and Dan Ward (litigation and enforcement partners) and Ellen Gilley, discuss how investment agreements can be powerful tools for companies with foreign investments to recover or prevent loss in response to public

On August 16, 2019, the Ninth Circuit upheld Amazon’s cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court’s 2017 decision. In essence, the holding confirms that U.S. companies transferring all intangibles to foreign subsidiaries need not include global goodwill and going concern value of the business when calculating the mandatory buy-in payment

It is no secret that cryptocurrency holders are facing increased scrutiny by the IRS. In 2018, the agency announced a virtual currency compliance campaign that included outreach and examinations. As part of its latest sequence this summer, the IRS recently publicized that it has begun sending letters to cryptocurrency holders advising them of their reporting