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In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise. Please refer to the following list of tax and tax controversy-related alerts and original articles for additional insight and guidance:

On May 12, 2020, the IRS released proposed regulations (REG-104591) affecting the deductibility of payments made to governments in settlement of alleged violations of law. The proposed regulations interpret Sections 162(f) and 6050X of the Internal Revenue Code of 1986 (the Code), as amended and introduced by the Tax Cuts and Jobs Act (TCJA), respectively.

Tax controversy group co-founder and tax partner Kat Gregor, tax controversy counsel Elizabeth Smith, tax controversy associate Isabelle Farrar and associate Andrew Yarrows recently co-authored an article that appeared in Bloomberg Tax. The article outlines some practical considerations for taxpayers and their advisers in light of federal and state taxing authorities’ enforcement-related responses to COVID-19.

The IRS launched a compliance campaign targeting issues arising out of the 2017 Tax Cuts and Jobs Act (“TCJA”) on May 1, 2020. The Large Business & International Division (“LB&I”) has released a number of issue-based compliance campaigns in recent years, including one targeting the so-called repatriation tax enacted under the TCJA in Internal Revenue

In a recent Law360 article, members of the international arbitration group, Kat Gregor (also tax partner and tax controversy group co-founder) Nick Berg and Dan Ward (litigation and enforcement partners) and Ellen Gilley, discuss how investment agreements can be powerful tools for companies with foreign investments to recover or prevent loss in response to public

German papers have called it the most complicated tax fraud trial in modern German history, but the “Cum-Ex” scandal could have implications for the entire financial services industry. Litigation & Enforcement  partners and attorneys Judith Seddon, Rosemarie Paul, Paige Berges and Chris Stott, along with Tax partners Kat Gregor and Andrew Howard

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

In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor examines a recent transfer pricing decision from the Western District of Washington, in which a Washington federal judge took a broad interpretation of what constitutes a tax shelter when he ordered Microsoft to turn over documents to the IRS.

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