On September 11, a Ropes & Gray team secured a significant victory on behalf of Veolia Energy Boston, Inc. in the Supreme Judicial Court of Massachusetts. Affirming a 2016 decision by the state Appellate Tax Board and denying the Boston Board of Assessors’ appeal, the court ruled that Veolia will be refunded $1.96 million in personal property taxes paid to the city of Boston. The court concluded that Veolia’s system of underground steam pipes was…

In a recent Law360 article, tax partner and tax controversy group co-founder Kat Gregor and tax controversy counsel Elizabeth Smith examine the top five modern tax challenges for digital health companies. Please click here to the read full article.…

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 and payment obligations and warning that failure to properly report transactions or pay taxes owed might result in penalties or…

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 Treasury Regulations §§ 1.482-7A(d)(2) and 1.482-7(d)(3). In Altera, a Ninth Circuit panel reversed a 2015 Tax Court decision invalidating the Treasury…

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. Click here to read the full article.…

IFA New England Breakfast Meeting: Ropes & Gray hosted an IFA Breakfast on May 23, which featured a presentation on the recent Danish beneficial ownership cases by Eric Fort, tax partner at Arendt & Medernach. 12th Annual U.S. and Latin American Tax Practice Trends Conference: Kat Gregor recently spoke on a panel of leading experts on “Hidden Wealth”: The Global Campaign for Tax Transparency –the Latin Response” on June 13 in Miami, Florida. Topics…

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 consumer sales tax class action suits will grow with the proliferation of states’ Wayfair sales tax collection regulations, and retailers’ struggling…