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On May 22, 2017, Ropes & Gray hosted a reception featuring Special Trial Judge Peter J. Panuthos of the U.S. Tax Court to re-launch the Boston Chapter of the FBA Tax Section. Read more about the event here, or if you’re interested in participating in or helping to organize a future event, please reach out directly to Gabby or Ryan at or

In February 2017, Ropes & Gray LLP published an article discussing recent reductions in the IRS budget and the resulting decline in enforcement, which has led to a gap of approximately $450 billion per year between the amount of tax that should be paid by U.S. taxpayers and the amount that is actually paid. The article also addressed possible changes to IRS funding in the new presidential administration.

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In January 2017, the IRS announced the rollout of thirteen compliance campaigns to be undertaken by its Large Business and International Division (“LB&I”). The campaigns are part of a broader effort by the IRS to reorient LB&I to focus on high-risk issues in order to more efficiently address non-compliance in an era of smaller IRS budgets and greater IRS responsibilities. The campaigns cover subjects including repatriation of overseas funds by U.S. taxpayers, related-party transactions, and TEFRA partnership examinations.

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In February 2017, Ropes & Gray LLP issued a client alert discussing material aspects of the proposed regulations released by the Department of Treasury implementing the partnership audit provisions of the Bipartisan Budget Act of 2015. The Bipartisan Budget Act rules created a new regime for auditing partnerships, repealing the Tax Equity and Fiscal Responsibility Act rules that have been in place since 1982. The proposed regulations provide much-needed guidance on a number of issues. Continue reading.

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In August 2016, Ropes & Gray LLP published an article commenting on IRS’s practice in seeking increasing amounts of discovery during the examination process, where IRS benefits from substantially looser enforcement standards than those available under the Federal and Tax Court Rules. Continue Reading Facebook Summons Controversy Deepens, Further Illustrating Divergent Standards Applicable to IRS Summons Enforcement and Court-Ordered Discovery

A hotly contested appeal regarding the IRS’s authority to promulgate regulations is underway in the Ninth Circuit. Last year, in Altera Corp. & Subsidiaries v. Comm’r, the Tax Court entered a unanimous reviewed decision invaliding, under Administrative Procedure Act (APA), a 2003 IRS transfer pricing rule limiting the availability of a safe harbor under Section 482.  145 T.C. 91 (2015).  Continue Reading Ninth Circuit Appeal in Altera Could Have Broad Implications for IRS’s Rule-Making Authority