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
Spring Newsletter 2020
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.
Published Guidance on Implementation of Families First Coronavirus Response Act
Update: On July 15, the Internal Revenue Service announced in news release IR-2020-158 that taxpayers who have experienced delays with the process of Form 7200, Advance Payment of Employer Credits Due To COVID-19 will receive letters. If the IRS rejected taxpayer’s Form 7200 or made a change to the requested amount of advance payment due to a computation error, the taxpayer will receive letter 6312 explaining the reason for rejection or list the new payment amount if the old amount was due to a computation error. The taxpayer will receive letter 6313 if the IRS needs written verification of the taxpayer’s current mailing address in order for the IRS to process the taxpayer’s Form 7200.
Update: On July 8, the Internal Revenue Service issued Notice 2020-54 as guidance for employers regarding the requirement to report amounts of qualified sick and family leave wages paid to employees under the Families First Coronavirus Response Act. Under Notice 2020-54, employers will be required to report payment to employees either on Box 14 of Form W-2, or in a separate statement. The notice also provides employers with language to use on Form W-2 or in the statement to employees. This reporting requirement is imposed to assist employees who are self-employed to properly claim their qualified sick and family leave equivalent credits.
On Friday, March 20, 2020, the Treasury Department, Internal Revenue Service, and the Department of Labor issued primary guidance on the Families First Coronavirus Response Act (the Act) (commonly referred to as Phase 2) in Notice IR-2020-57 (the Notice). Please see alert for discussion of two new important tax details provided in the Notice regarding the Act’s employer tax credits, and for additional discussion of the Act, generally. The two new important tax details are (1) that employers can be “paid” by retaining certain funds otherwise due to the government (including income tax withholding from ALL employees), and (2) that rebate requests will be processed by IRS within two weeks or less.…
Continue Reading Published Guidance on Implementation of Families First Coronavirus Response Act
How a Corporation Can Request a Federal Income Tax Refund
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), commonly referred to as Phase 3 of the federal government’s response to the coronavirus outbreak, was enacted on March 27, 2020. See Ropes & Gray Alerts on CARES Act, and certain key tax provisions of CARES Act. The CARES Act created opportunities for
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Federal, State Tax Authority Enforcement-Related Responses to Covid-19



R&G attorneys outline some practical considerations for taxpayers and their advisers in light of federal and state taxing authorities’ enforcement-related responses to COVID-19 in an article published in Bloomberg Tax.
Please click here to read the full article.
Podcast: Cross-selling in the Crosshairs: Implications and Challenges of the Oracle 401(k) Fee Litigation Settlement



In this Ropes & Gray podcast, litigation & enforcement partner Dan Ward, ERISA and benefits partner Josh Lichtenstein, and benefits principal David Kirchner discuss the recent $12 million settlement that has been agreed to in the Oracle 401(k) fee litigation, which includes some non-monetary requirements that could have a ripple effect on the routine…
IRS Has Launched Tax Reform Audit Campaign


The IRS launched a compliance campaign targeting issues arising out of the 2017 Tax Cuts and Jobs Act (“TCJA”) on May 1, 2020. The Large Business & International Division (“LB&I”) has released a number of issue-based compliance campaigns in recent years, including one targeting the so-called repatriation tax enacted under the TCJA in Internal Revenue…
Safeguarding Foreign Investments During A Pandemic



In a recent Law360 article, members of the international arbitration group, Kat Gregor (also tax partner and tax controversy group co-founder) Nick Berg and Dan Ward (litigation and enforcement partners), discuss how investment agreements can be powerful tools for companies with foreign investments to recover or prevent loss in response to public health crises and…
Virtual Board Meetings and Remote Work—Managing Unintended Tax Risks



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Are Privilege Protections Shifting in the Tax Context?



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