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

Disputing Tax

Tax Challenges Arising from Digitalisation — Report on the Pillar One Blueprint

By Kat Gregor & Elizabeth Julia Smith

January 7, 2021

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 — Report on the Pillar One Blueprint. The OECD’s Pillar One and Pillar Two proposals seek to change the taxation of…

Disputing Tax

Busy New Year: Predicted IRS Enforcement Trends in 2021

By Kat Gregor, Elizabeth Julia Smith & Isabelle Farrar

December 31, 2020

In a recent Bloomberg Tax article, tax partner and tax controversy group co-founder Kat Gregor, tax controversy counsel Elizabeth Smith and tax controversy associate Isabelle Farrar examine seven potential areas of focus for IRS enforcement in 2021, including TCJA-related audits and increased partnership tax compliance.…

Disputing Tax

Phase 4 Stimulus Package—Highlight of Certain Key Tax-Related Provisions in the Phase 4 Stimulus Package

By COVID-19 Developments Team

December 23, 2020

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 the Phase 4 Stimulus are summarized in this Alert, and include an expansion of the employee retention credit, an additional…

Disputing Tax

Upcoming & Noteworthy Tax Controversy Events

By Tax Controversy Team

December 23, 2020

Virtual ABA 2021 Midyear Tax Meeting: Brittany Cvetanovich will moderate “The Future of Impact Investment Funds” panel during the virtual ABA Midyear Tax Meeting on January 28, 2021. The panel will examine the current state of impact investment funds in light of a new adverse ruling issued to a fund manager that sought tax-exempt status. Virtual UT Law 2021 Nonprofit Organizations Institute: Brittany Cvetanovich moderated a session on “Impact Investing” during the UT…

Disputing Tax

In International Comparative Legal Guide – Corporate Tax 2021, Kat Gregor and Elizabeth Julia Smith Author Chapter on Taxing the Digitalizing Economy

By Kat Gregor & Elizabeth Julia Smith

December 16, 2020

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 their tax codes to capture revenue given the ways in which advanced technologies have changed the delivery of products and…

Disputing Tax

Massachusetts Extends COVID Guidance Relating to Sourcing of Employee Income

By Elizabeth Julia Smith & Isabelle Farrar

December 10, 2020

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 is that it will now remain in force until 90 days after the COVID-19 state of emergency in Massachusetts expires. …

Disputing Tax

Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)

By Leo Arnaboldi, Kat Gregor, Sara Clevering, Brian Harris, Hudson Todd & Lucas Caruso

December 9, 2020

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 the Code generally limits business interest expense deductions and was substantially revised by the Tax Cuts and Jobs Act (the…

Disputing Tax

Controversy Brewing Over Massachusetts Taxation of Nonresidents

By Elizabeth Julia Smith & Isabelle Farrar

December 8, 2020

The Massachusetts Department of Revenue (the “DOR”) finalized a regulation on October 21, 2020 (the “Regulation”) to address income-sourcing concerns during the COVID-19 pandemic. Pursuant to the Regulation, the DOR will continue to treat as Massachusetts-source income any compensation paid to a nonresident who currently performs services out of state due to the pandemic but, immediately prior to the pandemic, performed such services in Massachusetts. Accordingly, such income will be subject to Massachusetts personal income…

Disputing Tax

Quarterly Insights from Ropes & Gray

Blog Authors

Tax Controversy Coronavirus Thought Leadership

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

Tax Challenges Arising from Digitalisation — Report on the Pillar One Blueprint

Busy New Year: Predicted IRS Enforcement Trends in 2021

Phase 4 Stimulus Package—Highlight of Certain Key Tax-Related Provisions in the Phase 4 Stimulus Package

Upcoming & Noteworthy Tax Controversy Events

In International Comparative Legal Guide – Corporate Tax 2021, Kat Gregor and Elizabeth Julia Smith Author Chapter on Taxing the Digitalizing Economy

Massachusetts Extends COVID Guidance Relating to Sourcing of Employee Income

Updated Interest Deductibility Guidance Released by the IRS under Section 163(j)

Controversy Brewing Over Massachusetts Taxation of Nonresidents

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