Second Quarter Newsletter 2019

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

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in the same case that had previously been released by the Ninth Circuit on July 24, 2018, only to be precipitously withdrawn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

On March 21, 2019, the IRS announced it is temporarily suspending two revenue rulings addressing tax-free spinoffs. The suspended rulings had arguably required the distributing corporation and the spun-off corporation to each independently generate current revenue. This development is welcome news for life sciences, technology, and other research and development (R&D)-focused business organizations that did