In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise. Please refer to the following list of recent tax and tax controversy-related alerts and original articles for additional insight and guidance. For a comprehensive list of related thought leadership, please refer to the
COVID-19 Developments
Connecticut Provides 2020 Tax Relief for Telecommuting Employees



Connecticut has passed a bill that provides tax relief for 2020 only for employees working remotely who would have potentially had their wages taxed by two states (H.B. 6516) The bill provides particular relief to Connecticut residents who are required to pay income taxes for the 2020 tax year to other states that…
American Jobs Plan & Made in America Tax Plan—Summary of Certain Key Tax Components
On Wednesday March 31, 2021, President Joseph R. Biden announced the American Jobs Plan and Made in America Tax Plan, designed to provide dramatic improvements to U.S. infrastructure writ large. The American Jobs Plan will focus on physical infrastructure, climate change, domestic manufacturing, research and development (R&D), and home health care services. The plan proposes…
American Rescue Plan Act (ARPA) Phase 5 Stimulus Package—Highlights of Certain Key Tax-Related Provisions in ARPA
On March 11, 2021, President Biden signed into law the American Rescue Plan Act (ARPA), in furtherance of the fifth phase of the federal government’s response to the COVID-19 crisis. The full text of the bill is published here. The key tax provisions of the Phase 5 Stimulus are summarized in this Alert, and…
Tax Controversy Coronavirus Developments: Court, Federal and State-by-State Updates



In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise.
Consolidated Appropriations Act (CAA) Phase 4 Stimulus Package—Highlight of Certain Key Tax-Related Provisions in the CAA
On December 21, 2020, a bipartisan agreement was reached on the Consolidated Appropriations Act 2021 (CAA or Phase 4 Stimulus), in furtherance of the fourth phase of the federal government’s response to the COVID-19 crisis. (The bill was passed on December 21, 2020 by both the House of Representatives and the Senate.) The key tax…
Massachusetts Extends COVID Guidance Relating to Sourcing of Employee Income


On December 8, 2020, Massachusetts extended its COVID guidance relating to the sourcing of employee income that was set to expire on December 31, 2020, via emergency regulation 830 CMR 62.5A.3 and via technical information release TIR 20-15. (TIR 20-15 supersedes both TIR 20-10 and TIR 20-05.) The only change to the COVID guidance…
Controversy Brewing Over Massachusetts Taxation of Nonresidents
The Massachusetts Department of Revenue (the “DOR”) finalized a regulation on October 21, 2020 (the “Regulation”) to address income-sourcing concerns during the COVID-19 pandemic. Pursuant to the Regulation, the DOR will continue to treat as Massachusetts-source income any compensation paid to a nonresident who currently performs services out of state due to the pandemic but,…
When Down the Hall Becomes Across State Lines—Part 2


Many people relocated to a different state as Covid-19 pandemic restrictions intensified. That relocation may have lasted much longer than was anticipated and may have resulted in an unintended establishment of residency in another state. In Part 2 of a two-part series published in Bloomberg Tax, R&G attorneys explore common fact patterns and the…
When Down the Hall Becomes Across State Lines—Part 1


Many people relocated to a different state as Covid-19 pandemic restrictions intensified. That relocation may have lasted much longer than was anticipated and may have resulted in an unintended establishment of residency in another state. In Part 1 of a two-part series published in Bloomberg Tax, R&G attorneys explore several northeastern states’ tax residency…