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In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax associate Stefan Herlitz analyze the costly risks that loom if retailers collect too much sales tax including private class action lawsuits seeking refunds of over-collected sales tax.

The authors explain that the trend of

On June 7, 2019, the Ninth Circuit re-issued a decision in Altera v. Commissioner, upholding an IRS Regulation that had been previously struck down by the Tax Court.  (This follows a decision in the same case that had previously been released by the Ninth Circuit on July 24, 2018, only to be precipitously withdrawn

Kat Gregor was recently quoted in a Law360 article, “Foreign FATCA Criticism Unlikely To Spur Changes, which discussed how the U.S. Department of the Treasury is unlikely to change reporting requirements of the U.S. Foreign Account Tax Compliance Act in response to European complaints. Her remarks were also published in POLITICO Pro’sMorning Tax

In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and litigation associate Liz Tolon explore the tax privilege nuances associated with attorney-client privilege and other relevant analogs that exist to protect client confidentiality. Their article discusses applicable privileges in the tax context, as well as

On December 21, 2018, IRS and Treasury issued final regulations implementing the partnership audit regime (T.D. 9844). The final regulations largely adopt, with some changes, the proposed regulations issued in August 2018. By issuing almost 200 pages of preamble, the final regulations provide extensive discussion of which comments were incorporated and why others were

Data analysis is not a new concept, but it nonetheless is the center of a social and technological revolution. In recent months, we have gained significant insight into how the IRS and state taxing authorities are leveraging advanced technology and machine learning to mine the petabytes of taxpayer data that they collect and retain.

To