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​Tax partner Kat Gregor and tax associates Isabelle Farrar, Yulia Kirillova and Ningzhou Shen co-authored an article in Tax Notes Federal that examines how audit adjustments in the United States following litigation tied to Altera Corporation v. Commissioner could affect multinational corporations that have cost-sharing arrangements and file tax returns in multiple jurisdictions.

The four

On August 5, 2021 Senate Finance Committee Chairman Ron Wyden and Senator Sheldon Whitehouse introduced proposed legislation (the “Ending the Carried Interest Loophole Act,” or the “Proposal”) that would substantially change the U.S. federal income tax treatment of partnership interests issued in exchange for services, commonly known as carried interests, and potentially other types of

A recent Tax Notes article covers a Women of IFA Network International Fiscal Association USA (WIN-IFA) webinar that examined the details of the IRS’s latest compliance campaign on financial services entities engaged in a U.S. trade or business. The article includes insights from Kat Gregor, tax partner and tax controversy group co-founder. To read the

On June 10, 2021, the IRS’s Large Business and International Division (“LB&I”) announced a broad compliance campaign targeting “financial service entities engaged in a U.S. trade or business.” Through issue-based audits, the LB&I campaign will examine “whether foreign investors were subject to U.S. tax on effectively connected income from lending transactions engaged in through a

The U.S. Department of Treasury’s recent tax compliance proposals include measures that would ramp up reporting for large cryptocurrency transactions, likely streamlining tax enforcement around digital assets. Tax partner Kat Gregor discusses the proposals in a recent Law360 article. Please click here to read the full article.

Tax partner Kat Saunders Gregor  has been elected to the prestigious American College of Tax Counsel as a fellow. The College recognizes leading members of the Bar who have made significant contributions to the understanding and improvement of the U.S. tax system. Membership in the College is by nomination from a current fellow and an

Kat Gregor, tax partner and co-founder of the tax controversy group, was recently appointed to Law360’s 2021 Tax Authority International Editorial Advisory Board. In addition, Elizabeth Smith, tax controversy counsel, was recently appointed to Law360’s 2021 Tax Authority State & Local Editorial Advisory Board. The purpose of these boards, according to the announcements, is “to

In an International Bar Association (IBA) article, tax partner and tax controversy group co-founder Kat Gregor provides insight on the U.S. implications of the Organisation for Economic Cooperation and Development’s public consultation on its proposals to address the tax challenges of digitalization, blueprints for which were published in October 2020. Please click here to read