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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

Tax partner and tax controversy group co-founder Kat Gregor, senior tax attorney Ariella Mutchler and tax & benefits associate Ningzhou Shen co-authored an article recently published by Law360 titled “OECD Digital Tax Plan Shifts Tax Risk For Asset Managers.”

The piece examines how the Organisation for Economic Cooperation and Development (OECD)’s digital tax plan shifts

It is no secret that cryptocurrency holders are facing increased scrutiny by the IRS. In 2018, the agency announced a virtual currency compliance campaign that included outreach and examinations. As part of its latest sequence this summer, the IRS recently publicized that it has begun sending letters to cryptocurrency holders advising them of their reporting