In a recent Law360 article, Kat Gregor commented on the IRS’s final guidance on partnership audit rules. This new guidance finalizes a subset of the IRS rules implementing the audit regime passed in the 2015 Bipartisan Budget Act. A key aspect of the final rules is the definition of “partnership related items,” which looks to
US Attys Can’t Snub EU Tax Reporting Rules, Panelist Says
During the January 2019 ABA Tax Section 2019 Midyear Tax Meeting, Kat Gregor, tax partner and co-founder of the tax controversy group, discussed the new EU mandatory disclosure rules (known as DAC6 related to aggressive tax positions) and the ethical obligations of U.S. attorneys to adhere to these rules. Kat noted that “the EU rules
Podcast: Cum-Ex Dividend Trade Investigations
In this Ropes & Gray podcast, Alec Oveis, an associate in the tax and benefits group is joined by Kat Gregor, a partner in the tax group and co-founder of the tax controversy group, and Andy Howard, a partner in the tax group, to discuss the investigations now underway in Europe involving so-called “cum-ex
Trending Video: New Anti-Abuse Tax Provisions
Kat Gregor, tax partner and co-founder of the tax controversy group, examines the influx of new anti-abuse provisions around the world in this trending video.
Noteworthy Tax Controversy Events
Update on the Implementation of BEPS-inspired anti-avoidance measures: Kat Gregor was a featured panelist during the IBA’s October conference in Rome.
Treasury Issues Final Rules on Partnership Representatives and New Proposed Rules Under the Partnership Audit Regime
August 2018 brought two major developments in the Department of Treasury’s race to finalize its partnership audit reform regulations before partnerships begin in early 2019 filing tax returns for the first time under the new regime. First, on August 7, the Department of Treasury (“Treasury”) issued final regulations for partnership representatives. Second, on August 13,
BEPS Penalty Fallout
In a recent Tax Notes article, the author addresses a recent IBA conference panel focused on OECD’s implementation of the base erosion and profit-shifting (BEPS) program. Kat Gregor, who was a speaker on this panel, provides commentary on BEPS’ penalty fallout. Kat provides insight on the positive and negative implications of the program and notes
In Sudden About-Face, Ninth Circuit Withdraws Altera Decision Pending Further Discussions with New Panel Judge
As previously reported by Ropes & Gray, on July 24, 2018, the Ninth Circuit reversed the Tax Court’s prior decision in the Altera case and upheld the IRS regulation requiring the allocation of stock-based compensation in qualified cost-sharing agreements. The decision was particularly notable since it ended in a 2-1 vote, in which Judge Reinhardt,
9th Circuit Altera Decision Could Warrant Rare En Banc Review
In a recent Law360 article, Kat Gregor provides insight on the Ninth Circuit’s ruling in the Altera case. The article analyzes what factors might lead to a reconsideration of the decision—a rare en banc review. If the decision stands, billions of dollars are at stake for multinational corporations. With this idea in mind, Kat noted
Tax Law Still Leaves Room for Companies to Write off Settlement Agreements
In two recent Bloomberg Law articles, Kat Gregor comments on rules governing deductibility of payments enacted to governments as part of 2017 tax reform, including deporting requirements under section 6050X of the Code. The purpose of these new guidelines is to “boost transparency in corporate settlements and make it easier for the IRS to keep