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 tax and tax controversy-related alerts and original articles for additional insight and guidance:
In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise.
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,
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 this episode of Ropes & Gray’s podcast series, Disputing Tax, Ellen Gilley, an associate in the tax controversy group, is joined by Kat Gregor, a tax partner and tax controversy group co-founder, and Brittany Cvetanovich, counsel in the tax group, to discuss a recent Federal Circuit case, Charleston Area Medical Center, Inc. v.
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