In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise. Please refer to the following list of recent tax and tax controversy-related alerts and original articles for additional insight and guidance. For a comprehensive list of related thought leadership, please refer to the
Connecticut Provides 2020 Tax Relief for Telecommuting Employees
Connecticut has passed a bill that provides tax relief for 2020 only for employees working remotely who would have potentially had their wages taxed by two states (H.B. 6516) The bill provides particular relief to Connecticut residents who are required to pay income taxes for the 2020 tax year to other states that
IRS Issues Final Regulations on Deductions of Certain Settlement Payments to Governments
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
Joint Chiefs of Tax Enforcement to Investigate Tax Fraud Arising Out of FinTech and Cryptocurrency
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 Controversy Coronavirus Developments: Court, Federal and State-by-State Updates
In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise.
Busy New Year: Predicted IRS Enforcement Trends in 2021
In a recent Bloomberg Tax article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax controversy associate Isabelle Farrar examine seven potential areas of focus for IRS enforcement in 2021, including TCJA-related audits and increased partnership tax compliance.
Massachusetts Extends COVID Guidance Relating to Sourcing of Employee Income
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
Controversy Brewing Over Massachusetts Taxation of Nonresidents
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,
Final BEAT Regulations Contain Promise and Pitfalls for Taxpayers
On September 3, the Department of the Treasury issued final regulations regarding the base erosion and anti-abuse tax (“BEAT”) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties.[1] The final regulations provide guidance on a number of areas, an important section of the regulations pertains to the
Updates in IRS’ Ongoing Enforcement Against Syndicated Conservation Easements
The IRS has been closely scrutinizing syndicated conservation easements since December 2017. In 2020, there have been some important developments in this area. First, in June 2020 the IRS announced a time-limited settlement opportunity for certain docketed Tax Court cases. Second, in August and September 2020, the Senate Finance Committee issued a report and data