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Tax partner and tax controversy group co-founder Kat Gregor and tax controversy group counsel Elizabeth Smith were participants in the International Bar Association (IBA) Working Group that submitted comments to the OECD Centre for Tax Policy and Administration regarding the OECD/G20 Inclusive Framework on BEPS Public Consultation Document entitled Tax Challenges Arising from Digitalisation —

Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled “Taxing the Digitalizing Economy: Corporate Tax Laws and Regulations 2021.” A link to the chapter is here.

The chapter looks at how jurisdictions around the world are attempting to adapt

On July 28, 2020, the Treasury Department and the IRS issued final and proposed regulations (the “Final Regulations” and “New Proposed Regulations”) under Section 163(j) of the Internal Revenue Code (the “Code”). The Final Regulations and New Proposed Regulations amend prior proposed regulations issued on November 26, 2018 (the “Prior Proposed Regulations”). Section 163(j) of

In a recent Tax Notes article, tax partner and tax controversy group co-founder Kat Gregor provides commentary on the IRS Large Business and International Division’s transition tax compliance campaign, also commonly referred to as the Section 965 campaign, which is causing some taxpayer headaches when it comes to the audit review of earnings and profits