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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

In the wake of the IRS’ Ninth Circuit victory in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Circuit 2019), the IRS’ Large Business and International (LB&I) Division issued Memorandum LB&I-04-0719-008, informing examiners that they may once again open examinations to require taxpayers to include stock-based compensation costs as intangible development costs under

In Law360, tax partner and tax controversy group co-founder Kat Gregor discusses the top summer book recommendations for tax attorneys, including “First: Sandra Day O’Connor” by Evan Thomas and “How to Win in a Winner-Take-All World: The Definitive Guide to Adapting and Succeeding in High-Performance Careers” by Neil Irwin.

Click here to read the

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

Tax partner and tax controversy group co-founder Kat Gregor recently spoke on a panel of leading experts on “Hidden Wealth”: The Global Campaign for Tax Transparency –the Latin Response” at the 12th Annual U.S. and Latin America Tax Practice Trends Conference on June 13th in Miami, Florida. Topics included the Common Reporting System (CRS);