Third Quarter Newsletter 2018

In a recent Law360 article, Kat Gregor comments on a recent Treasury Inspector General for Tax Administration report that highlights the IRS’ stalled enforcement of the Foreign Account Tax Compliance Act (“FATCA”). This stalled enforcement demonstrates that although the agency has cracked down on unreported offshore accounts, there are associated logistical challenges that must considered.

As previously described in part in Disputing Tax and in a recent Bloomberg article that included remarks from Kat Gregor, Facebook has been involved in a multi-front litigation with the IRS for almost two years.  It began when Facebook refused to extend the statute of limitations for a sixth time to allow the IRS to continue to its nearly five-year long audit of Facebook for the tax years 2008 to 2010.  The IRS responded by filing suit to enforce a summons and then by issuing a Notice of Deficiency alleging that Facebook owed additional tax as a result of its $7 billion undervaluation of certain intangibles transferred to Facebook Ireland.  Facebook appealed the Notice of Deficiency in Tax Court and also filed two separate lawsuits in the U.S. District Court for the Northern District of California.
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In a recent Law360 article, Kat Gregor comments on current and future tax obligations Meghan Markle, Duchess of Sussex, should consider as a U.S. citizen living abroad and married to a non-U.S. resident. Kat notes that the Duchess is still responsible for reporting and paying taxes on her worldwide income in accordance with Section 61

In a recent The Drawdown article, “Tax Comes Under ESG Spotlight,” tax partner Andrew Howard provides commentary on how companies might approach assessing reputational risks from tax decisions in the ESG global arena. Howard notes, that in light of recent attitude shifts toward tax transparency, we may see “policymakers bring forth rules that erode confidentiality