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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

…

Final BEAT Regulations Contain Promise and Pitfalls for Taxpayers

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By Stefan Herlitz on November 13, 2020
Posted in Fall Newsletter 2020

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…

Notice 2020-75: The SALT Cap Does Not Apply to Income Tax Payments Made by Partnerships and S Corporations (in contrast to actual payments made by a partner or S corporation shareholder)

Photo of Lee AllisonPhoto of Janice Lee
By Lee Allison & Janice Lee on November 10, 2020
Posted in Fall Newsletter 2020

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…

When S Corporations Should Elect Entity Treatment for GILTI Purposes

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By Bob Kane on November 3, 2020
Posted in Fall Newsletter 2020

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.

IRS Memo Sheds Light on Process for Designating Cases for Litigation

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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.…

When Down the Hall Becomes Across State Lines—Part 2

Photo of Lee Allison
By Lee Allison on October 23, 2020
Posted in COVID-19 Developments, Fall Newsletter 2020

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…

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…

When Down the Hall Becomes Across State Lines—Part 1

Photo of Lee Allison
By Lee Allison on October 22, 2020
Posted in COVID-19 Developments, Fall Newsletter 2020

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…

Updates in IRS’ Ongoing Enforcement Against Syndicated Conservation Easements

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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

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By Brenda Coleman, 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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  • Upcoming and Noteworthy Tax Controversy Events
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