Photo of Elizabeth Julia Smith

Tax partner and tax controversy group co-founder Kat Gregor and tax controversy group counsel Elizabeth Smith were participants in the International Bar Association (IBA) Working Group that submitted comments to the OECD Centre for Tax Policy and Administration regarding the OECD/G20 Inclusive Framework on BEPS Public Consultation Document entitled Tax Challenges Arising from Digitalisation —

Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled “Taxing the Digitalizing Economy: Corporate Tax Laws and Regulations 2021.” A link to the chapter is here.

The chapter looks at how jurisdictions around the world are attempting to adapt

On December 8, 2020, Massachusetts extended its COVID guidance relating to the sourcing of employee income that was set to expire on December 31, 2020, via emergency regulation 830 CMR 62.5A.3 and via technical information release TIR 20-15.  (TIR 20-15 supersedes both TIR 20-10 and TIR 20-05.) The only change to the COVID guidance

On August 6, 2020, the IRS issued proposed regulations (REG-132434-17) limiting the role of contractors hired to assist the IRS in audits, including during summons interviews. The proposed regulations implement Section 7602(f), enacted by the Taxpayer First Act (P.L. 116-25), which became effective on July 1, 2019. They withdraw and replace proposed regulations

After the Supreme Court declined to review the Ninth Circuit’s decision in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Cir. 2019) (cert denied — S. Ct. — (June 22, 2020)), the IRS has confirmed that it is examining taxpayers that did not include stock-based compensation costs as intangible development costs under Treasury

The IRS has announced that it will begin enforcing Section 965’s repatriation tax in October 2020. Section 965 and its regulations require United States shareholders to pay a one-time transition tax on untaxed foreign earnings of certain foreign corporations as if these earnings had been repatriated to the United States. Cash holdings are taxed at

Mornings are different, all around the country — and world.

Due to travel limitations imposed in response to the COVID-19 crisis, instead of taking trains, buses and cars to commute to work, people are going to work at home. This new work location has created concerns for both businesses and individuals as to what authority