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.
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
In Notice 2020-75, the Treasury/IRS announced that proposed regulations will be issued to provide certainty that income tax payments made by partnerships and S corporations (as opposed to flowing through the tax to, and with payment then made by, each actual partner or S corp shareholder) are deductible without being subject to the SALT
In a recent Tax Notes Federal article, tax associate Bob Kane analyzes Notice 2020-69 and the S corporations and shareholders that would benefit from electing entity treatment for the global intangible low-taxed income (GILTI) regime.
Please click here to read the full article.
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.
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
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
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
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
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