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On June 10, 2021, the IRS’s Large Business and International Division (“LB&I”) announced a broad compliance campaign targeting “financial service entities engaged in a U.S. trade or business.” Through issue-based audits, the LB&I campaign will examine “whether foreign investors were subject to U.S. tax on effectively connected income from lending transactions engaged in through a

Tax authorities around the globe have focused on combatting tax evasion and other financial crimes associated with cryptocurrency in recent years. More recently, investigative efforts have broadened to include the FinTech industry. In late March 2021, the Joint Chiefs of Tax Enforcement—or the J5—held a coordinated international tax investigation into the FinTech industry and cryptocurrency.

Kat Gregor, tax partner and co-founder of the tax controversy group, was recently appointed to Law360’s 2021 Tax Authority International Editorial Advisory Board. In addition, Elizabeth Smith, tax controversy counsel, was recently appointed to Law360’s 2021 Tax Authority State & Local Editorial Advisory Board. The purpose of these boards, according to the announcements, is “to

In a recent FCPA Professor guest post, tax partner and tax controversy group co-founder Kat Gregor, litigation partner Ryan Rohlfsen, litigation senior attorney Yana Grishkan, and tax controversy counsel Elizabeth Smith examine how the final regulations interpreting Section 162(f) of the Code released on January 14, 2021 impact the deduction of amounts paid to the

On January 14, 2021, the IRS released final regulations (T.D. 9946) (the “Final Regulations”) interpreting Sections 162(f) and 6050X of the Internal Revenue Code of 1986 (the “Code”), as amended and drafted by the Tax Cuts and Jobs Act (“TCJA”), respectively. As described below, the Final Regulations deviate from and clarify proposed regulations that the

An upcoming international criminal tax investigation coordinated by the Joint Chiefs of Tax Enforcement—or the J5—will focus on cryptocurrency and the financial technology industry. The J5 is a collaboration among the revenue authorities of Australia, Canada, the Netherlands, the U.K., and the U.S. formed in 2018 that leverages the agencies’ collective resources to target financial

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 —