Tax partner and tax controversy group co-founder Kat Gregor, senior tax attorney Ariella Mutchler and tax & benefits associate Ningzhou Shen co-authored an article recently published by Law360 titled “OECD Digital Tax Plan Shifts Tax Risk For Asset Managers.” The piece examines how the Organisation for Economic Cooperation and Development (OECD)’s digital tax plan shifts tax risk for asset managers. The tax plan, referred to as “pillar one,” creates a new tax right that is…

On November 4, 2019, the IRS announced that the LB&I division will begin examining 2017 and 2018 tax returns for compliance with the so-called repatriation tax under Internal Revenue Code Section 965. The examinations will target US-based multinational companies. Please click here to read the full alert.…

In a corporate tax special report by Financier Worldwide Magazine, tax partner and tax controversy group co-founder Kat Gregor and tax controversy associate Ellen Gilley co-authored a piece that discusses international arbitration as a new avenue for challenging tax enforcement. Please click here to read the full article.…

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…