Third Quarter Newsletter 2019

On August 16, 2019, the Ninth Circuit upheld Amazon’s cost-sharing arrangement and valuation of its intangible assets, affirming the Tax Court’s 2017 decision. In essence, the holding confirms that U.S. companies transferring all intangibles to foreign subsidiaries need not include global goodwill and going concern value of the business when calculating the mandatory buy-in payment

It is no secret that cryptocurrency holders are facing increased scrutiny by the IRS. In 2018, the agency announced a virtual currency compliance campaign that included outreach and examinations. As part of its latest sequence this summer, the IRS recently publicized that it has begun sending letters to cryptocurrency holders advising them of their reporting

In the wake of the IRS’ Ninth Circuit victory in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Circuit 2019), the IRS’ Large Business and International (LB&I) Division issued Memorandum LB&I-04-0719-008, informing examiners that they may once again open examinations to require taxpayers to include stock-based compensation costs as intangible development costs under

In Law360, tax partner and tax controversy group co-founder Kat Gregor discusses the top summer book recommendations for tax attorneys, including “First: Sandra Day O’Connor” by Evan Thomas and “How to Win in a Winner-Take-All World: The Definitive Guide to Adapting and Succeeding in High-Performance Careers” by Neil Irwin.

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In “The Practitioner’s Guide to Global Investigations” half-year update, Global Investigations Review published a piece authored by litigation and enforcement partner Judith Seddon titled “HMRC outlines benefits of self-reporting tax offences, while SFO fraud guidance expected to reward privilege waiver and compliance programmes.” Judith and litigation and enforcement partner Ama Adams served as