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
Stefan Herlitz
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Threat Of Sales Tax Overcollection Suits Grows Post-Wayfair
By Stefan Herlitz on
Posted in Summer Newsletter 2019
In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax associate Stefan Herlitz analyze the costly risks that loom if retailers collect too much sales tax including private class action lawsuits seeking refunds of over-collected sales tax.
The authors explain that the trend of…
States Follow the IRS in Joining the Big Data Revolution
By Stefan Herlitz on
Posted in Spring Newsletter 2019
Data analysis is not a new concept, but it nonetheless is the center of a social and technological revolution. In recent months, we have gained significant insight into how the IRS and state taxing authorities are leveraging advanced technology and machine learning to mine the petabytes of taxpayer data that they collect and retain.
To…