The Massachusetts Department of Revenue (the “DOR”) finalized a regulation on October 21, 2020 (the “Regulation”) to address income-sourcing concerns during the COVID-19 pandemic. Pursuant to the Regulation, the DOR will continue to treat as Massachusetts-source income any compensation paid to a nonresident who currently performs services out of state due to the pandemic but,
IRS Memo Sheds Light on Process for Designating Cases for Litigation
The IRS recently published a memorandum that provides guidance on the process of designating certain cases or issues for litigation (the “IRS Memo”). When a case or issue is designated for litigation, a taxpayer’s ability to try to resolve that issue through the IRS Independent Office of Appeals (“Appeals”) is foreclosed.
Proposed Regulations Restrict Role of IRS Contractors in Audits and Summons Interviews
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
IRS Has Begun Examining Stock-Based Compensation Cost-Sharing Arrangements
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
IRS to Begin Enforcing Section 965 Transition Tax in October
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
Key Tax Considerations For Cos. With Remote Employees
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
Tax Court Hearings Will Be Conducted Remotely
U.S. Tax Court proceedings will soon resume, however, they will do so entirely remotely until further notice as a result of the COVID-19 pandemic. On May 29, the Tax Court announced that via Press Release that all proceedings would be conducted remotely, and that proceedings would be available to the public via telephone dial-in. The
IRS Issues Proposed Regulations on Deductions of Certain Settlement Payments to Governments
On May 12, 2020, the IRS released proposed regulations (REG-104591) affecting the deductibility of payments made to governments in settlement of alleged violations of law. The proposed regulations interpret Sections 162(f) and 6050X of the Internal Revenue Code of 1986 (the Code), as amended and introduced by the Tax Cuts and Jobs Act (TCJA), respectively.
Federal, State Tax Authority Enforcement-Related Responses to Covid-19
R&G attorneys outline some practical considerations for taxpayers and their advisers in light of federal and state taxing authorities’ enforcement-related responses to COVID-19 in an article published in Bloomberg Tax.
Please click here to read the full article.
IRS Has Launched Tax Reform Audit Campaign
The IRS launched a compliance campaign targeting issues arising out of the 2017 Tax Cuts and Jobs Act (“TCJA”) on May 1, 2020. The Large Business & International Division (“LB&I”) has released a number of issue-based compliance campaigns in recent years, including one targeting the so-called repatriation tax enacted under the TCJA in Internal Revenue