Please refer to the following list of recent tax and tax controversy-related COVID-19 alerts in addition to original articles for insight and guidance pertaining to updates from the Biden Administration. For a comprehensive list of related thought leadership, please refer to the COVID-19 landing page.
Tax partner Kat Gregor and tax associates Isabelle Farrar, Yulia Kirillova and Ningzhou Shen co-authored an article in Tax Notes Federal that examines how audit adjustments in the United States following litigation tied to Altera Corporation v. Commissioner could affect multinational corporations that have cost-sharing arrangements and file tax returns in multiple jurisdictions.
The four
In Bloomberg Tax, tax associates Isabelle Farrar, Alec Oveis, Phillip Popkin, and Joshua Thomas evaluate new IRS guidance regarding employee retention credits which are included in various legislative pandemic relief packages. The tax attorneys summarize the IRS notices, explaining guidance on how businesses can simultaneously take advantage of both Paycheck Protection Program (PPP) loans
Tax authorities around the globe have focused on combatting tax evasion and other financial crimes associated with cryptocurrency in recent years. More recently, investigative efforts have broadened to include the FinTech industry. In late March 2021, the Joint Chiefs of Tax Enforcement—or the J5—held a coordinated international tax investigation into the FinTech industry and cryptocurrency.
In this episode of Ropes & Gray’s podcast series Disputing Tax, Isabelle Farrar, an associate in the tax controversy group, is joined by Kat Gregor, a tax partner and tax controversy group co-founder, and Elizabeth Smith, counsel in the tax controversy group, to examine some potential areas of focus for IRS enforcement efforts in
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
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
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
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.
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