In a recent FCPA Professor guest post, tax partner and tax controversy group co-founder Kat Gregor, litigation partner Ryan Rohlfsen, litigation senior attorney Yana Grishkan, and tax controversy counsel Elizabeth Smith examine how the final regulations interpreting Section 162(f) of the Code released on January 14, 2021 impact the deduction of amounts paid to the
Amendment to D.C. False Claims Act Will Allow Tax Actions, Enhancing Tax Enforcement in the District
In mid-March, amendments to the D.C. False Claims Act (the “D.C. Act”) providing for tax fraud enforcement under the Act will become effective unless Congress vetoes the reforms before that time. Among other changes, the amended D.C. Act will allow private citizen whistleblowers to bring lawsuits, on behalf of the District, against taxpayers who have
IRS Issues Final Regulations on Deductions of Certain Settlement Payments to Governments
On January 14, 2021, the IRS released final regulations (T.D. 9946) (the “Final Regulations”) interpreting Sections 162(f) and 6050X of the Internal Revenue Code of 1986 (the “Code”), as amended and drafted by the Tax Cuts and Jobs Act (“TCJA”), respectively. As described below, the Final Regulations deviate from and clarify proposed regulations that the
Tax Challenges Arising from Digitalisation — Report on the Pillar One Blueprint
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 —
Busy New Year: Predicted IRS Enforcement Trends in 2021
In a recent Bloomberg Tax article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax controversy associate Isabelle Farrar examine seven potential areas of focus for IRS enforcement in 2021, including TCJA-related audits and increased partnership tax compliance.
In International Comparative Legal Guide – Corporate Tax 2021, Kat Gregor and Elizabeth Julia Smith Author Chapter on Taxing the Digitalizing Economy
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
Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)
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
Transition Tax Campaign’s Focus on E&P Concerns Practitioners
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
Final BEAT Regulations Contain Promise and Pitfalls for Taxpayers
On September 3, the Department of the Treasury issued final regulations regarding the base erosion and anti-abuse tax (“BEAT”) imposed on certain large corporate taxpayers with respect to certain payments made to foreign related parties.[1] The final regulations provide guidance on a number of areas, an important section of the regulations pertains to the
Podcast: Disputing Tax: What is a Corporation? Charleston Area Medical Center and the New Carried Interest Regulations
In this episode of Ropes & Gray’s podcast series Disputing Tax, Franziska Hertel, an associate in the tax practice, is joined by Kat Gregor, a tax partner and tax controversy group co-founder, and Brittany Cvetanovich, counsel in the tax practice, to discuss a recent Federal Circuit case, Charleston Area Medical Center, Inc. v. United