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Tax Controversy Coronavirus Thought Leadership

By Kat Gregor, Isabelle Farrar & COVID-19 Developments Team

October 23, 2020

In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise. Please refer to the following list of tax and tax controversy-related alerts and original articles for additional insight and guidance: Tax Controversy Coronavirus Developments: Court, Federal and State-by-State Updates (Last Updated October 19, 2020) When Down the Hall Becomes Across State Lines—Part 2 When Down the Hall Becomes Across State Lines—Part 1 Controversy Brewing …

Disputing Tax

When Down the Hall Becomes Across State Lines—Part 2

By Lee Allison, Kat Gregor & Andrew Yarrows

October 23, 2020

Many people relocated to a different state as Covid-19 pandemic restrictions intensified. That relocation may have lasted much longer than was anticipated and may have resulted in an unintended establishment of residency in another state. In Part 2 of a two-part series published in Bloomberg Tax, Lee Allison, Kat Saunders Gregor, and Andrew Yarrows explore common fact patterns and the impact of certain variables that may affect outcomes Please click here to read the full…

Disputing Tax

When Down the Hall Becomes Across State Lines—Part 1

By Lee Allison, Kat Gregor & Andrew Yarrows

October 22, 2020

Many people relocated to a different state as Covid-19 pandemic restrictions intensified. That relocation may have lasted much longer than was anticipated and may have resulted in an unintended establishment of residency in another state. In Part 1 of a two-part series published in Bloomberg Tax, Lee Allison, Kat Saunders Gregor, and Andrew Yarrows explore several northeastern states’ tax residency requirements and the potential for taxation by multiple states. Please click here to read the…

RopesDataPhiles

British Airways Fined £20 Million by ICO for Data Breach

By Rohan Massey, Clare Sellars & Edward Machin

October 20, 2020

On 16 October 2020, in a long-awaited decision, the UK Information Commissioner’s Office (ICO) finally announced that it has fined British Airways (BA) £20 million for failing to protect the personal and financial details of over 400,000 customers. The ICO originally announced in July 2019 its intention to fine BA £183 million in respect of a security breach, meaning that the final amount of the fine was over 90% lower than the original suggested amount. …

Patents Post-Grant

White House Pushes Back on PTAB Rule Making Effort

By Scott McKeown

October 19, 2020

Agency to Consider Further Public Comment Over the past few months, Congress has been asked to investigate the Patent Trial & Appeal Board’s (PTAB) practice of denying AIA trial petitions in view of competing litigations. On top of that, the agency has been sued for applying these allegedly unlawful practices, and there is a mandamus pending on the same issues at the Federal Circuit. In parallel, the agency had been pursuing a draft rule…

Disputing Tax

Tax Controversy Coronavirus Developments: Court, Federal and State-by-State Updates

By Isabelle Farrar, Eunice Um & Andrew Yarrows

October 19, 2020

In response to the Coronavirus (COVID-19), the tax controversy group has put together a chart detailing tax controversy-related developments as they arise.…

Patents Post-Grant

PTAB Bounces RPX on Unique RPI Relationships

By Scott McKeown

October 15, 2020

RPX Business Dealings With Salesforce Result in RPI Snafu Earlier this month, the PTAB issued its remand decision in RPX Corp. v. Applications In Internet Time, LLC (here). As a reminder, the Federal Circuit (pre-Thryv) instructed the PTAB to further analyze under a more “flexible approach” whether Salesforce was a real party-in-interest (RPI) to two RPX-filed IPR petitions. On remand, the Board held that Salesforce was an RPI, and that the petitions at issue…

Patents Post-Grant

Arthrex Cert Likely to Spur Previously Discussed Legislative Fix

By Scott McKeown

October 13, 2020

Review of APJ Appointments to Be Considered by SCOTUS Back in November of 2019 the House Judiciary Committee conducted a hearing entitled “The Patent Trial and Appeal Board and the Appointments Clause: Implications of Recent Court Decisions.” The hearing explored whether or not the Federal Circuit solution pronounced in Arthrex was effective to cure the Appointments Clause defect. While there was some debate over whether the “fix” would hold, all of the witnesses were…

RopesDataPhiles

What the CJEU Missed in Schrems II: American Agencies Respond

By Brendan Kearney

October 9, 2020

The Court of Justice of the European Union (CJEU) dealt a blow to transatlantic data flows in July with its decision in Schrems II, invalidating the EU-U.S. Privacy Shield while conditionally approving the continued use of Standard Contractual Clauses (SCC). In a white paper published late last month, the U.S. government responded to the CJEU’s critical appraisal of American intelligence agencies’ data-collection practices by identifying Schrems II’s shortcomings and offering guidance to companies…

Disputing Tax

Updates in IRS’ Ongoing Enforcement Against Syndicated Conservation Easements

By Isabelle Farrar, Andrew Yarrows & Sabrina Cohn

October 8, 2020

The IRS has been closely scrutinizing syndicated conservation easements since December 2017. In 2020, there have been some important developments in this area. First, in June 2020 the IRS announced a time-limited settlement opportunity for certain docketed Tax Court cases. Second, in August and September 2020, the Senate Finance Committee issued a report and data quantifying the amounts that syndicated conservation easements have allegedly cost the U.S. government. Third, some affected taxpayers have filed a…

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Tax Controversy Coronavirus Thought Leadership

When Down the Hall Becomes Across State Lines—Part 2

When Down the Hall Becomes Across State Lines—Part 1

British Airways Fined £20 Million by ICO for Data Breach

White House Pushes Back on PTAB Rule Making Effort

Tax Controversy Coronavirus Developments: Court, Federal and State-by-State Updates

PTAB Bounces RPX on Unique RPI Relationships

Arthrex Cert Likely to Spur Previously Discussed Legislative Fix

What the CJEU Missed in Schrems II: American Agencies Respond

Updates in IRS’ Ongoing Enforcement Against Syndicated Conservation Easements

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