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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,

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

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,

In an unexpected 2-1 decision, Judge Reinhardt, who passed away in March of this past year, cast the Ninth Circuit’s deciding vote to reverse the Tax Court’s prior ruling in Altera. In 2015, the Tax Court invalidated Treasury Regulation 1.482-7A(d)(2)’s requirement that related parties allocate stock-based compensation costs when entering into cost-sharing agreements to

In a recent Law360 article, Kat Gregor comments on a recent Treasury Inspector General for Tax Administration report that highlights the IRS’ stalled enforcement of the Foreign Account Tax Compliance Act (“FATCA”). This stalled enforcement demonstrates that although the agency has cracked down on unreported offshore accounts, there are associated logistical challenges that must considered.