Winter Newsletter 2020

Tax partner and tax controversy group co-founder Kat Gregor and tax controversy group counsel Elizabeth Smith were participants in the International Bar Association (IBA) Working Group that submitted comments to the OECD Centre for Tax Policy and Administration regarding the OECD/G20 Inclusive Framework on BEPS Public Consultation Document entitled Tax Challenges Arising from Digitalisation —

On December 21, 2020, a bipartisan agreement was reached on the Consolidated Appropriations Act 2021 (Phase 4 Stimulus), in furtherance of the fourth phase of the federal government’s response to the COVID-19 crisis. (The bill was passed on December 21, 2020 by both the House of Representatives and the Senate.) The key tax provisions of

Tax partner Kat Gregor and tax counsel Elizabeth Julia Smith published a chapter in the International Comparative Legal Guide – Corporate Tax 2021 entitled “Taxing the Digitalizing Economy: Corporate Tax Laws and Regulations 2021.” A link to the chapter is here.

The chapter looks at how jurisdictions around the world are attempting to adapt

On December 8, 2020, Massachusetts extended its COVID guidance relating to the sourcing of employee income that was set to expire on December 31, 2020, via emergency regulation 830 CMR 62.5A.3 and via technical information release TIR 20-15.  (TIR 20-15 supersedes both TIR 20-10 and TIR 20-05.) The only change to the COVID guidance

On July 28, 2020, the Treasury Department and the IRS issued final and proposed regulations (the “Final Regulations” and “New Proposed Regulations”) under Section 163(j) of the Internal Revenue Code (the “Code”). The Final Regulations and New Proposed Regulations amend prior proposed regulations issued on November 26, 2018 (the “Prior Proposed Regulations”). Section 163(j) of