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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

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

On August 6, 2020, the IRS issued proposed regulations (REG-132434-17) limiting the role of contractors hired to assist the IRS in audits, including during summons interviews. The proposed regulations implement Section 7602(f), enacted by the Taxpayer First Act (P.L. 116-25), which became effective on July 1, 2019. They withdraw and replace proposed regulations

After the Supreme Court declined to review the Ninth Circuit’s decision in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Cir. 2019) (cert denied — S. Ct. — (June 22, 2020)), the IRS has confirmed that it is examining taxpayers that did not include stock-based compensation costs as intangible development costs under Treasury

The IRS has announced that it will begin enforcing Section 965’s repatriation tax in October 2020. Section 965 and its regulations require United States shareholders to pay a one-time transition tax on untaxed foreign earnings of certain foreign corporations as if these earnings had been repatriated to the United States. Cash holdings are taxed at