On May 16, 2019, the Large Business and International (LB&I) Division of the IRS unveiled the Large Corporate Compliance (LCC) program. The LCC uses data analytics to automatically target the largest and most complex corporate taxpayers having the most compliance risks for examination. The LCC is part of a larger push toward “portfolio management”—ensuring that
Threat Of Sales Tax Overcollection Suits Grows Post-Wayfair
In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax associate Stefan Herlitz analyze the costly risks that loom if retailers collect too much sales tax including private class action lawsuits seeking refunds of over-collected sales tax.
The authors explain that the trend of
Elizabeth Smith Moderates a Panel at the ABA Section of Taxation May Meeting
Tax controversy counsel Elizabeth Smith recently moderated a panel of leading experts on “Administrative Practice Committee Important Developments” at the ABA Section of Taxation May Meeting on May 10 in Washington D.C. Topics included, Treasury and IRS guidance and regulations, court decisions, and other items germane to tax administration. Please click here to view the
A Brief Exploration Of Privilege Nuances In The Tax Context
In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and litigation associate Liz Tolon explore the tax privilege nuances associated with attorney-client privilege and other relevant analogs that exist to protect client confidentiality. Their article discusses applicable privileges in the tax context, as well as
States Follow the IRS in Joining the Big Data Revolution
Data analysis is not a new concept, but it nonetheless is the center of a social and technological revolution. In recent months, we have gained significant insight into how the IRS and state taxing authorities are leveraging advanced technology and machine learning to mine the petabytes of taxpayer data that they collect and retain.
To
Podcast: Texas v. United States of America
In this Ropes & Gray podcast, Isabelle Farrar, a senior associate in the tax controversy group is joined by Harvey Cotton, a principal in the tax and benefits group, and Elizabeth Smith, counsel in the tax controversy group, to discuss the December 2018 decision from the Northern District of Texas in Texas v. United
Amazon Notifies Marketplace Sellers that It Will Disclose Their Inventory Information to the Massachusetts Department of Revenue
In late January 2018, Amazon notified its third party marketplace sellers with inventory in Massachusetts that the company planned to turn over information regarding them to the Massachusetts Department of Revenue. Amazon informed the vendors that the information, to be disclosed by January 26, 2018, would include name, address, phone number, federal tax ID number, and an estimated value of the vendor’s inventory stored in Amazon warehouses located in Massachusetts based on the seller’s prices in late 2016 and 2017. Amazon has had one fulfillment center in Massachusetts, in Fall River, since fall of 2016.
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