Second Quarter Newsletter 2019

In its 2019 Spring Term, the Supreme Court published five decisions regarding tax matters, three of which limit states’ taxing authority. In a February decision, Dawson v. Steager, the Court held that a state cannot tax a federal retiree’s pension benefits while declining to tax a similarly situated state retiree. The March decision in

The IRS will continue to focus its compliance efforts on taxpayers’ offshore activities in the coming months.

At the June 2019 New York University Tax Controversy Forum, acting director of IRS field operations (foreign payments practice) Kimberly A. Schoenbacher stated that the IRS will soon launch a compliance campaign targeting foreign banks that have not

On May 16, 2019, the Large Business and International (LB&I) Division of the IRS unveiled the Large Corporate Compliance (LCC) program. The LCC uses data analytics to automatically target the largest and most complex corporate taxpayers having the most compliance risks for examination. The LCC is part of a larger push toward “portfolio management”—ensuring that

In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax associate Stefan Herlitz analyze the costly risks that loom if retailers collect too much sales tax including private class action lawsuits seeking refunds of over-collected sales tax.

The authors explain that the trend of

Tax partner and tax controversy group co-founder Kat Gregor recently spoke on a panel of leading experts on “Hidden Wealth”: The Global Campaign for Tax Transparency –the Latin Response” at the 12th Annual U.S. and Latin America Tax Practice Trends Conference on June 13th in Miami, Florida. Topics included the Common Reporting System (CRS);

On June 7, 2019, the Ninth Circuit re-issued a decision in Altera v. Commissioner, upholding an IRS Regulation that had been previously struck down by the Tax Court.  (This follows a decision in the same case that had previously been released by the Ninth Circuit on July 24, 2018, only to be precipitously withdrawn

Kat Gregor was recently quoted in a Law360 article, “Foreign FATCA Criticism Unlikely To Spur Changes, which discussed how the U.S. Department of the Treasury is unlikely to change reporting requirements of the U.S. Foreign Account Tax Compliance Act in response to European complaints. Her remarks were also published in POLITICO Pro’sMorning Tax

Tax controversy counsel Elizabeth Smith recently moderated a panel of leading experts on “Administrative Practice Committee Important Developments” at the ABA Section of Taxation May Meeting on May 10 in Washington D.C. Topics included, Treasury and IRS guidance and regulations, court decisions, and other items germane to tax administration. Please click here to view the