In this Ropes & Gray podcast, Elizabeth Smith, counsel in the tax controversy group, is joined by David Saltzman, a partner in the tax group, to discuss the recent Tax Court memorandum decision, Illinois Tool Works Inc. & Subsidiaries
Disputing Tax
Quarterly Insights from Ropes & Gray
Disputing Tax, published by Ropes & Gray, focuses on legal issues related to tax controversies and disputes. The blog covers topics such as tax litigation, IRS enforcement, tax settlements, and regulatory developments affecting taxpayers and tax professionals. It also addresses emerging areas like digital asset taxation, international tax compliance, and the impact of new tax legislation and directives on various industries, including private equity and retirement plans. The blog provides analysis of court decisions, government policies, and tax authority guidance relevant to tax dispute resolution and compliance strategies.
Latest from Disputing Tax - Page 10
IRS Considers Giving More Ventures Access to Tax-Free Spinoffs
By David Saltzman & Ben Rogers
On September 25, 2018, the IRS announced that it is considering guidance on the treatment of spinoffs involving business ventures engaged in research and development for future profit. The announcement is of special interest to life sciences and other technology
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Impact of environmental, social and governance agenda on tax
Tax partner Andrew Howard recently recorded a Ropes & Gray trending video, in which he addresses tax coming out of the shadows and becoming a part of the environmental, social and governance (ESG) agenda.
In Sudden About-Face, Ninth Circuit Withdraws Altera Decision Pending Further Discussions with New Panel Judge
As previously reported by Ropes & Gray, on July 24, 2018, the Ninth Circuit reversed the Tax Court’s prior decision in the Altera case and upheld the IRS regulation requiring the allocation of stock-based compensation in qualified cost-sharing agreements. The…
Ninth Circuit Upholds IRS Regulation on Allocation of Stock-Based Compensation, Reversing the Tax Court
In an unexpected 2-1 decision, Judge Reinhardt, who passed away in March of this past year, cast the Ninth Circuit’s deciding vote to reverse the Tax Court’s prior ruling in Altera. In 2015, the Tax Court invalidated Treasury Regulation 1.482-7A(d)(2)’s
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Are California’s Economic Sourcing Rules The Next Wayfair?
Move over, South Dakota v. Wayfair Inc. During the long debate over the U.S. Supreme Court’s physical presence standard for state sales taxes, a quiet revolution in state corporate income taxes has been taking place — the shift to market-based…
Case of the Quarter–South Dakota v. Wayfair
By Kat Gregor
In this Ropes & Gray podcast, Brittany Cvetanovich, an associate in the tax group, is joined by Kat Gregor, tax partner and co-founder of the tax controversy group, to discuss a notable Supreme Court decision, South Dakota v. Wayfair. On
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Virtual Currencies and the Commodity Trading Safe Harbor
Tax partner Jim Brown and tax associate Franziska Hertel authored a recent Tax Notes Special Report article, in which they analyzed whether the commodity trading safe harbor is available to foreign investors engaging in virtual currency trades. The IRS has…
The Bell Tolls for Quill’s Physical Presence Standard
On June 21, 2018, the Supreme Court ruled 5-4 in South Dakota v. Wayfair et al. that the Constitution does not prevent the State of South Dakota from requiring large online retailers without actual physical presence in the state to…
New IRS Compliance Campaign Focuses on Reporting of Foreign Trusts
On May 21, 2018, the IRS Large Business & International Division (“LB&I”) announced its fourth set of compliance campaigns. The six new campaigns include one campaign centered on Forms 3520 and 3520-A compliance. A Form 3520, Annual Return To Report…