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Fall Newsletter 2020

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Coronavirus Thought Leadership and Updates from the Biden Administration

By COVID-19 Developments Team on December 16, 2021
Posted in COVID-19 Developments, Fall Newsletter 2020, Spring Newsletter 2020, Spring Newsletter 2021, Summer Newsletter 2020, Summer Newsletter 2021, Winter Newsletter 2020, Winter Newsletter 2022

Please refer to the following list of recent tax and tax controversy-related COVID-19 alerts in addition to original articles for insight and guidance pertaining to updates from the Biden Administration. For a comprehensive list of related thought leadership, please refer to the COVID-19 landing page.

  • Large IRAs and High-Income Retirement Savers Targeted by Amendment

…

IRS Memo Sheds Light on Process for Designating Cases for Litigation

Photo of Richard Rowley
By Richard Rowley on October 29, 2020
Posted in Fall Newsletter 2020

The IRS recently published a memorandum that provides guidance on the process of designating certain cases or issues for litigation (the “IRS Memo”). When a case or issue is designated for litigation, a taxpayer’s ability to try to resolve that issue through the IRS Independent Office of Appeals (“Appeals”) is foreclosed.…

Upcoming & Noteworthy Tax Controversy Events

By Tax Controversy Team on October 23, 2020
Posted in Fall Newsletter 2020

 New England SALT Forum: Ropes & Gray is a sponsor of the 2020 Virtual New England State and Local Tax Forum on November 17-19.

“Apparent Transparency–BEPS Actions 12 & 13,” TEI Annual Conference: On October 27, Kat Gregor was a co-panelist on “Apparent Transparency–BEPS Actions 12 & 13” during the 75th Annual Virtual…

Updates in IRS’ Ongoing Enforcement Against Syndicated Conservation Easements

Photo of Sabrina Cohn
By Sabrina Cohn on October 8, 2020
Posted in Fall Newsletter 2020

The IRS has been closely scrutinizing syndicated conservation easements since December 2017. In 2020, there have been some important developments in this area. First, in June 2020 the IRS announced a time-limited settlement opportunity for certain docketed Tax Court cases. Second, in August and September 2020, the Senate Finance Committee issued a report and data…

EU Blacklist – Cayman Islands off, Anguilla and Barbados on: Impact for Asset Managers

Photo of Andrew HowardPhoto of Chris Agnoli
By Andrew Howard & Chris Agnoli on October 6, 2020
Posted in Fall Newsletter 2020

In a keenly anticipated development the Cayman Islands was removed from the EU list of non-cooperative tax jurisdictions (the “EU blacklist”) on 6 October 2020 after adopting reforms relating to private funds in September 2020.

This will be welcome news for asset managers with Cayman entities in their structures as their tax compliance concerns return…

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  • U.S. Executive Order on the Development of Digital Assets
  • Damages From Inherently Physical Injuries Are Not Taxable
  • Upcoming and Noteworthy Tax Controversy Events
  • New LB&I Campaign Consistent with Increased IRS Focus on Partnership Tax Compliance
  • Hughes v. Northwestern University: Key Takeaways for 401(k) and 403(b) Plan Sponsors and Fiduciaries

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