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 tax and tax controversy-related alerts and original articles for additional insight and guidance:
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
In two decisions issued on July 9, 2020, the Supreme Court addressed challenges to several subpoenas that sought the President’s financial records, including tax returns. In a case concerning a subpoena issued by a state district attorney’s office, the Court held that a sitting president is not categorically immune from issuance of a subpoena in
In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise.
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
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.
Tax controversy group co-founder and tax partner Kat Gregor, tax controversy counsel Elizabeth Smith, tax controversy associate Isabelle Farrar and associate Andrew Yarrows recently co-authored an article that appeared in Bloomberg Tax. The article outlines some practical considerations for taxpayers and their advisers in light of federal and state taxing authorities’ enforcement-related responses to COVID-19.
On January 17, 2020, a federal district court in Washington ordered Microsoft Corporation (“Microsoft”) to produce many documents to the Internal Revenue Service (“IRS”) that Microsoft asserted were privileged. Microsoft had argued that most of the documents were protected by protected by the work product doctrine and the federally authorized tax practitioner privilege set forth
In this Ropes & Gray podcast, Isabelle Farrar, an associate in the tax controversy group, is joined by Elizabeth Smith, counsel in the tax controversy group, and Jennifer Romig, a partner in the health care group, to discuss the state taxation of digital products, an evolving area in several states. Specifically, they will discuss
On October 9, 2019, IRS released Revenue Ruling 2019-24, 2019-44 IRB, which provides new guidance on the Service’s handling of cryptocurrencies and is the first of such guidance to be released since March 2014 when IRS issued Notice 2014-21. The ruling was issued after prodding from a bipartisan congressional coalition. The ruling, and attached Frequently