Fourth Quarter Newsletter 2018

August 2018 brought two major developments in the Department of Treasury’s race to finalize its partnership audit reform regulations before partnerships begin in early 2019 filing tax returns for the first time under the new regime. First, on August 7, the Department of Treasury (“Treasury”) issued final regulations for partnership representatives. Second, on August 13,

In a recent International Financial Law Review article, tax partner Jim Brown provides insight on how the IRS has joined tax authorities from the UK, Canada, the Netherlands and Australia to create the Joint Chiefs of Global Tax Enforcement, a sign regulators are getting serious about cryptocurrency. Jim notes that there are questions on how

In a recent Tax Notes article, the author addresses a recent IBA conference panel focused on OECD’s implementation of the base erosion and profit-shifting (BEPS) program. Kat Gregor, who was a speaker on this panel, provides commentary on BEPS’ penalty fallout. Kat provides insight on the positive and negative implications of the program and notes

On October 1, Charles Rettig began his term as 49th Commissioner of the IRS. This gives the IRS a Commissioner for the first time in approximately one year, since his predecessor John Koskinen, an Obama appointee, stepped down in fall 2017. David Kautter, the Treasury Department’s assistant secretary for tax policy, had been running the IRS in the interim.

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In this Ropes & Gray podcast, Ben Simmons, an associate in the tax group, is joined by David Saltzman, a partner in the tax group, to discuss the recent Tax Court memorandum decision, Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue. This case involved a strategy designed to permit a U.S.

On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research and development for future profit. The announcement is of special interest to life sciences and other technology ventures actively engaged in R&D for new pharmaceutical, medical device or other technology-based products. In